The West Lake Landfill is located near the city of St. Louis in Bridgeton, St. Louis County, Missouri. The site has been used,since 1962 for disposing of municipal refuse,>industrial solid and liquid wastes, and construction demolition debris.

This report summarizes the circumstances of the radioactive material in the West Lake Landfill. The radioactive material resulted from the processing of uranium ores and the subsequent sale by the AEC{of processing residues. Primary emphasis is on the radiological environmental aspects as they relate to potential disposition of the material. It is concluded that remedial action is called for.

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CONTENTS ABSTRACT 1 INTRODUCTION AND BACKGROUND 2 DESCRIPTION OF THE SITE . .

This report summarizes the circumstances of the radioactive material in the West Lake Landfill (Figure 1), in particular, [the radiological environmental aspects as they relate to potential disposition of the material.

The West Lake Landfill, Inc. property is a 200 acre tract in Bridgeton, St. Louis County, Missouri, on the outskirts of the city of St. Louis. It is about 4 miles West of St. Louis' Lambert Field! International Airport, near the intersection of interstate highways 1-70 and 1-270. Limestone was quarried there from 1939 to 1987. Also on the property is an industrial complex where concrete ingredients are measured and combined', and where asphalt aggregate is prepared. Since 1962, portions of the property have been used as landfills for disposing of municipal refuse, industrial solid and liquid wastes, and construction demolition debris. In 1973, soil contaminated with radioactive material was placed in a landfill there. i The radioactive material originated with uranium-ore-processing residues which had been stored at Lambert Airport by the U.S.{Atomic Energy Commission (AEC), and which were sold in early 1966 to the Continental Mining and Milling Company, of Chicago, Illinois. The AEC's invitation to bid listed the following residues for purchase: 74,000 tons of Belgian Congo pitchblende raffinate containing about 113 tons of uranium; 32,500 tons of Colorado raffinate containing about 48 tons of uranium; and 8700 tons of leached barium sulfate containing about 7 tons of uranium. The material was moved from the airport during 1966 to nearby 9200 Latty Avenue, Hazelwood, Missouri. In January 1967, the Commercial Discount Corporation of Chicago took possession of the residues to remove moisture and to ship the residues to the Cotter Corporation facilities in Canon City, Colorado. In December 1969, the remaining material was sold to the Cotter Corporation. In the following four years, the residues, with the principal exception of the 8700 tons of leached barium sulfate, were shipped to Canon City.1
In April 1974, Region III representatives of NRC's Office of Inspection and Enforcement visited the Cotter Corporation's Latty Avenue site to check on the progress of the decommissioning activitiesIbeing performed there. This inspection disclosed that in 1973 Cotter Corporation had disposed of approximately 8700 tons of leached barium sulfate residues mixed with 39,000 tons of top soil at a local landfill.1 j

By letter dated June 2, 1976, the Missouri Department of Natural Resources (MDNR) forwarded to the NRC's Region III office newspaper articles which alleged that only 9000 tons of waste had been moved from the Latty Avenue site rather than 40,000 tons and that it was moved to the West Lake Landfill rather than to the St. Louis Landfill No. 1. Region III personnel investigated the allegations and found that 43,000 tons of waste and soil had been removed from the Latty Avenue site and had been dumped at the West Lalce Landfill in Bridgeton, and that the waste was covered with only about 3 feet of soil.1
Discussion with the West Lake Landfill operators indicated that all of the material from Latty Avenue had been disposed ol in one area; however, an aerial

Figure 1 Location of West Lake Landfill

survey of the site Identified two areas of contamination. The second contaminated area Is Identified as Area 1 In Figure 2.2 Subsequently, the NRC sponsored other studies that were directed at determining the radiological status of the landfill. An extensive survey was initiated in November 1980 by the Radiation Management Corporation (RMC) under contract to the NRC. The findings were published in May 1982 in NUREG/CR-2722, "Radiological Survey of the West Lake Landfill, St. Louis County, Missouri."4 in March 1983, the NRC through Oak Ridge Associated Universities (ORAL)) contracted with the University of MissouriColumbia (UMC), Department of Civil Engineering, to describe the environmental characteristics of the site, conduct an engineering evaluation, and propose possible remedial measures for dealing with the radioactive waste at the West Lake Landfill. In May 1986, ORAU sampled water from wells on and close to the landfill to determine if the radioactive jnaterjial had migrated into the groundwater. A report is being prepared detailing the results of the investigations conducted by UMC and ORAU.2 Information from all these sources and from NRC site visits forms the basis for this report.
2 DESCRIPTION OF THE SITE

Location
The 200-acre West Lake Landfill site is situated on the southwest side of 2 St. Charles Rock Road in Bridgeton, St. Louis jCounty, Missouri (Figure I). It is about 16 miles northwest of the downtown area of the city of St. Louis, and about 4 miles west of Lambert Field International Airport (Figure 1). It is approximately 1.2 miles from the Missouri River.
History

The West Lake Landfill has been used since 1962 for the disposal of municipal refuse, Industrie? solid and liquid wastes, and construction demolition debris. Between 1939 and the spring of 1987, limestone was quarried there. Landfill operations filled in some of the excavated pitjs from the quarry operations. Also on the property is an active industrial complex in which concrete ingredients are measured and combined before mixing ("batching"), and asphalt aggregate is prepared. The unregulated landfill, in which the radioactive material was placed in 1973, was closed in 1974 by the Missouri Department of Natural Resources (MDNR). Also in 1974, under an MDNR permit, a newer sanitary landfill was opened and now operates in an adjacent area on the West liake Landfill property. The newer landfill is protected from groundwater contact. The bottom of the new landfill is lined with clay, and a leachate collection system has been installed. Leachate is pumped to a treatment system consisting of a lime precipitation unit followed in series by an aerated lagoon and two unaerated lagoons. The final lagoon effluent is discharged into St. Louis Metropolitan Sewer District sewers.2
Ownership

Since 1939, the West Lake Landfill has been owned by West Lake Landfill, Inc., of 13570 St. Charles Rock Road, Bridgeton, Missouri.

LEGEND
— — — Landfill Boundary

Berm
O Monitoring Well

MISSOURI RIVER FLOODPLAIN '

Laachata Collection Well

Ra 226 exceeds 5pCi/g
Sole in 100

0

60

ISO

200

GROUNDWATER GRADIENT

WEST LAKE LANDFILL

OS2

051
HISTORICAL EDGE OF ALLUVIAL VALLEY

Figure 2 Site Details

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Contaminated Areas

Radioactive contamination at the West Lake Landfill has been identified in two separate soil bodies (Figure 2).

The northern area (referred to as Area 2) covers about 13 acres3 and lies above 16 to 20 feet of landfill debris. The contaminated soil forms a more or less continuous layer from 2 to 15 feet in thickness and consists of approximately 130,000 cubic yards of soil. Some of this contaminated soil is near or at the surface, particularly along the face of the northwestern bertn. Beneath the landfill debris, the soil profile consists of 3 to 7 feet of floodplain top soil overlying; 30 to 50 feet of sand and gravel alluvium.
The southern area of contamination (Area 1) covers about 3 acres3 and contains roughly 20,000 cubic yards of contaminated soijl. This body of soil is located east of the landfill's main office at a depth of about 3 to 5 feet and is located over a former quarry pit which was filleil in with debris. The depth of debris beneath the contaminated soil is unknown but is estimated to be 50 to 65 feet. Limestone bedrock underlies the landfill debris.2

Topography
About 75 percent of the landfill site is located on the floodplain of the Missouri River (Figure 2) at about 440 feet above mean sea level (msl). The site topography is subject to change because of the types of activities (e.g., landfill ing and quarrying) performed there. However, the areas containing the radioactive waste have their surface at about 470 feet (msl). The surface runoff in the area around the landfill follows several surface drains and ditches that run in a northwest direction and drain into the Missouri River.2

Geology
Bedrock beneath the West Lake Landfill consists of limestone that extends downward to an elevation of 190 feet msl. The limestone is dense, bedded, and except for intermittent layers that consist of(abundant chert nodules, fairly pure. The Warsaw Formation, which lies directly beneath the limestone, is made up of approximately 40 feet of slightly calcareous, dense shale; this grades into shaley limestone toward the middle of the formation. Bedrock beneath the site dips at an angle of 0.5° to the northeast, Five miles east of the site, the attitude of the bedrock is reversed by the Florissant Dome.2

Since groundwater moving through carbonate rocks often creates channels for rapid water flow, the possibility of this occurring in the West Lake Landfill area was considered. Brief observation of the quarry walls at the landfill suggests that some of the limestone has dissolved. In a letter to West Lake Landfill, Inc., the Missouri Department of Natural Resources stated that the fact that grouting was necessary in the quarry area to block water inflow suggests that the limestone 1s at least somewhat solution weathered.4 However, in the draft UMC report, the opinion is expressed that the solution activity has apparently been limited to minor widening of joints and bedding planes near the bedrock surface, and that, at depth and when undisturbed, the limestone is 2 fairly impervious. It is not clear whether the views represented by these statements are in conflict.

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Soil material in the area may be divided into two categories: Missouri River alluvium and upland loessal soil. This demarcation is shown as the historical edge of the alluvial valley in Figure 2. The division is made on the basis of soil composition, depositional history, and physical properties. The West Lake Landfill lies over this transition zone.2

Hydrology
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Groundwater flows in the area surrounding the West Lake site through two aquifers: the Missouri River alluvium and the shallow limestone bedrock. Although the limestone is fairly impervious and groundwater flows in most areas from the bedrock into the alluvium, contamination of water in the bedrock aquifer is possible. The base of the limestone aquifer is formed by the relatively impermeable Warsaw shale at an elevation of about 190, feet (msl). This shale layer has been reached, but not disturbed, by quarrying operations. Therefore, the Warsaw shale acts as an aquiclude, making contamination of the deeper limestone unlikely. ] The deep Missouri River alluvium, which is under about 10 feet of more-recent alluvium, acts as a single aquifer of very high permeability. This aquifer is relatively homogeneous in a downstream direction' and decreases in permeability near the valley walls.
The the the the water table of the Missouri River floodplain1 is generally within 10 feet of ground surface, but at many points it is even shallower. At any one time, water levels and flow directions are influenced by both the river stage and amount of water entering the floodplain from adjacent upland areas.

Water levels recorded between November 1983 and March 1984 in monitoring wells at the landfill, indicate a groundwater gradient of 0.005 flowing in a N 30°W direction beneath the northern portion of the landfill. This represents the likely direction of leachate migration from the landfill.

Since no other recharge sources exist above the level of the floodplain, the only water available to leach the landfill debris is that resulting from rainfall infiltrating the landfill surface. Because the underlying alluvial aquifer is highly permeable, there will be littlje "mounding" of water beneath the landfill. Also, the northern portion of the landfill has a level surface, and thus it is likely that at least half of the rainfall infiltrates the surface. The remaining rainfall is lost to evapotranspiration and (to a lesser degree) surface runoff.2
No public water supplies are drawn from the alluvial aquifer near the West Lake Landfill. It is believed that only one private [well in the vicinity of the landfill is used as a drinking-water supply. This well is 1.4 miles N 35°W of the Butler-type building on the West Lake Landfill.

Because of the extremely low slope of the Missouri River floodplain surface, rain falling on the plain itself generally infiltrates the soil rather than running off the surface. The only streams present on the floodplain are those that originate in upland areas. Drainage patterns on the plain have been radically altered by flood control measures taken to protect Earth City and by drainage of swamps and marshes. Because of the relationship that exists

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between river level and groundwater level in portions of the floodplain near the river, streams may either lose flow (at low stage) or gain flow (at high stage).

The present channel of the Missouri River lies just under 2 miles west and northwest of the landfill. The Missouri River stage at St. Charles (mile 28) is zero for a water level of 413.7 feet (msl).i Average discharge of the Missouri River is 77,338 cubic feet per second. Water supplies are drawn from the Missouri River at mile 29 for the city of St. Charles, and the intake is located on the\north bank of the river. Another intake at mile 20.5 is for the St. Louis Waterj Company's North County plant. The city of St. Louis takes water from the Mississippi River, which is joined by the Missouri River downstream from the landfill. The intake structures for St. Louis are on the east bank of the river, so that the water drawn is derived from the upper Mississippi.2
Demography

Two small residential communities are present near the West Lake Landfill: Spanish Lake Village consists of about 90 homes and is located 0.9 mile south of the landfill, and a small trailer court lies across St. Charles Rock Road, 0.9 mile southeast of the site. Subdivisions are presently being developed 1 to 2 miles east and southeast of the landfill in the hills above the floodplain. Ten or more houses lie east of the landfill, scattered along Taussig Road. The city of St. Charles is located north of the Missouri River, more than 2 miles from the landfill.2 Population density on the floodplain is generally less than 26 persons per square mile, but the daytime population (including factory workers) is much greater than the number of full-time residents. Earth City Industrial Park is located on the floodplain 0.9 to 1.2 miles northwest of the landfill. The Ralston-Purina \ facilities are located 0.2 mile northeast of ihe Butler-type building at the landfill. Considering that land in this area is relatively inexpensive and that much of it is zoned for manufacturing, industrial development on the floodplain will likely increase.2
3 RADIOLOGICAL SURVEYS

From August 1980 through the summer of 1981, the Radiation Management Corporation (RMC), under contract to the NRC, performed an onsite evaluation of the West Lake Landfill3 to define the radiological conditions at the landfill. The results were utilized in performing this determination regarding whether or not remedial actions should be taken. The area to be surveyed was divided into 33-foot grid blocks and included the following measurements: (1) (2) (3) external gamma exposure rates 3.3 feet above the ground surface and beta-gamma count rates 0.4 inch above the surface; radionuclide concentrations in surface soils; radionuclide concentrations in subsurface deposits;

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(4)

total ("gross") activity and radionuclide concentrations in surface and subsurface water samples;

(7) total activity in vegetation.
External Gamma
The two areas of elevated external (gamma) radiation levels, as they existed in November 1980 at the time of the preliminary RMC site survey, both contained places where levels exceeded 100 uR per hour at 3.3 feet. In Area 2, gamma levels as high as 3000 to 4000 uR per hour were detected. The total areas exceeding 20 |jR per hour were about 2 acres in Area 1 and 9 acres in Area 2.3 (The criterion of 20 uR per hour is derived from the NRC's Branch Technical Position, 46 FR 52061, October 23, 1981, which aims at exposure rates less than 10 uR per hour above background levels; background radiation was taken to be 10 uR per hour also.) i

External gamma levels were measured in May and July of 1981. These levels were significantly smaller than the November 1980 values, especially in Area 1, because approximately 4 feet of sanitary fil\ had been added to the entire area, and an equal amount of construction fill was added to most of Area 2. As a result, only a few thousand square feet in Area 1 exceed 20 uR per hour. In Area 2, the total area exceeding 20 uR per hour decreased by about 10 percent, and the highest levels were about 1600 uR per hour near the Butler-type building.3 Surface Soil Analysis

A total of 61 surface soil samples were gathered and analyzed on site for gamma activity. Concentrations of U-238, Ra-226, Ra-223, Pb-211, and Pb-212 were determined for each sample. In all soil samples, only uranium and/or thorium decay chain nuclides and K-40 were detected. Offsite background samples were on the order of 2 pCi per gram for Ra-226. Onsite samples ranged from about 1 to 21,000 pCi Ra-226 per gram and from less than 10 to 2100pCi U-238 per gram. In samples in which elevated levels of Ra-226 were detected, the concentrations of U-238 were generally one-half to one-tenth of those of Ra-226. In cases of elevated sample activity, daughter products of both U-238 and U-235 were found.3
In general, surface activity was limited to Area 2, as indicated by the surface beta-gamma measurements. Only two small regions in Area 1 showed surface contamination; both were near the access road across from the site offices. In addition to onsite gamma analyses, 12 samples were submitted to RMC's rad'iochemical laboratories for thorium and uranium radiochemical determinations. The results of these measurements (Table 4 of NUREG/CR-2722) show that all samples contained high levels of Th-230. The ratio of Th-230 to Ra-226 (inferred from Bi-214) generally ranges from 4:1 to 40:1.

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Subsurface Soil Analysis

Subsurface contamination was assessed by extensive "logging" of holes drilled through the landfill. Several holes were drilled in areas known to contain contamination, then additional holes were drilled at intervals in all directions until no further contamination was detected. A total of 43 holes were drilled (11 in Area 1 and 32 in Area 2), including 2 offsite wells for monitoring water. All holes were drilled with a 6-inch auger and were lined with 4-inch PVC (polyvinyl chloride) casing.3 Each hole was scanned with a 2-inch Nal(Tl) detector and rate meter system for an initial indication of the location of subsurface contamination. On the basis of the initial scans, 19 holes were selected for detailed ganuna logging using the intrinsic germanium (IG) detector and multiple channel analyzer. Concentrations of Ra-226, as determined by the IG system, ranged from less than 1 pCi per gram to 22,000'pCi per gram.3 It was determined that the subsurface deposits extended beyond areas in which surface radiation measurements exceeded the reference level of 20 uR per hour.. The lateral extent of material exceeding 5 pCi Ra-226 per gram, including both surface and buried materials, is shown on Figure 2. The total difference in areas is about 5 acres.
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The surface elevations vary by about 20 feet/ and the highest elevations occur
at locations of more recent fill. Contaminated soil (>5 pCi Ra-226 per gram) is found from the surface to depths as great as 20 feet below the surface. In general, the contamination appears to be a continuous single layer ranging from 2 to 15 feet thick and covering 16 acres.3 Nonradiological Analysis Six composite samples were submitted to RMC's Environmental Chemistry Laboratory for priority pollutant analysis. Five samples were taken from auger holes (one from Area 1 and four from Area 2) and the sixth was taken from sludge from the West Lake Landfill leachate treatment plant. The analysis shows organic solvents present in the Area 2 samples. Positive results were reported for 25 listed organic compounds. Chromium, copper, lead, nickel, and zinc were the

predominant elemental priority pollutants detected. The analysis of the sample from the leachate treatment sludge showed that 3 it had smaller pollutant concentrations than the samples from the auger holes.
Chemical analyses of material from the radioactive layer from both areas were also performed by RMC's laboratory. In most cases, elevated levels of barium

and lead were found.
Background Radioactivity Measurement Several offsite locations (within a few miles of the West Lake Landfill) were selected for reference background measurements. Background values were all

within the normal range. The gamma exposure rates were 8 and 10.6 uR per hour.;
Radium-226 concentrations in soil were 2.5 and 2.6 pCi per gram. Radon flux from the ground surface was 0.50 and 0.58 pCi3per square meter-second; working level values were 0.0011, 0.0017, and 0.005 WL.

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Airborne Radioactivity Analysis
Both gaseous and particulate airborne radioactivity were sampled and analyzed during this study. Since it was known that the buried material consisted partially or totally of uranium ore residues, the sampling program concentrated on measuring radon'and its daughters in the air. Two methods were used: the first was a scintillation flask (accumulator) method for radon gas, and the second was analysis of filter paper activity for particulate daughters. A series of grab samples using the accumulator method were taken between May and August of 1981. A total of 111 samples from 32 locations were collected. Measurable radon flux levels ranged from 0.2 pCi per square meter-second in low background areas to 865 pCi per square meter-second in areas of surface contamination.3

At three locations, measurements were repeated over a period of 2 months. Significant fluctuations were observed at two locations. The fact that these fluctuations were real and not measurement artifacts was later confirmed by duplicate charcoal canister samples. A set of 10-minute, high-volume, particulate, air samples was taken to determine both short-lived radon daughter concentrations and long-lived gross alpha activity. The highest levels (0.031 WL) were detected in November 1980, near and inside the Butler-type building. These two samples approximately equal NRC's 10 CFR Part 20, Appendix B, alternate concentration limit of one-thirtieth WL for unrestricted areas. In addition to the routine 10-minute samples, five 20-minute, high-volume, air samples were taken" and counted immediately on the IG gamma spectroscopy system to detect the presence of Rn-219 daughters. All samples were taken near surface contamination. Concentrations of Rn-219 daughters ranged from 6 x 10-11 to 9 x 10-10 uCi per cubic centimeter.3

Vegetation Analysis

Vegetation samples collected by RMC included weed samples from onsite locations and farm crop samples (winter wheat) near the northwest boundary of the landfill. This location was chosen because water could run off from the fill onto the farm field. No elevated activities were found in these samples.3
Water Analysis
A total of 37 water samples were taken by RMC and analyzed for gross alpha and beta activity. Four samples were taken in the fall of 1980 and the remainder in the spring and summer of 1981. One sample was equal to the U.S. Environmental Protection Agency (EPA) gross-alpha-activity standard for drinking water of 15 pCi per liter and that was a sample of standing water near the Butler-type building. Several samples, including all the leachate treatment plant samples, exceeded the EPA drinking water action level'for gross beta activity. Subsequent isotopic analyses indicated that the beta activity could be attributed to K-40. None of the offsite samples exceeded either EPA standard.3
In 1981, the Missouri Department of Natural Resources collected 41 water samples that RMC analyzed for radioactivity. Of these samples, 5 were background, 10 were onsite surface water, 10 were shallow groundwater standing in boreholes, and 16 were landfill leachate. From these data, background activity is estimated as 1.5 pCi gross alpha activity per liter and 30 pCi gross beta activity per liter. One groundwater sample was at 15 pCi gross alpha per liter, and one 10

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surface water sample was 45 pCi per liter. Most of the leachate samples were above 50 pCi beta per liter.3

In addition, groundwater samples in 11 perimeter monitoring wells at the West Lake Landfill were taken by the Reitz and Jens Engineering firm on November 15, 1983, and by University of Missouri at Columbia (UMC) personnel on March 21, 1 9 8 4 . In both sampling times, one well, but not the same one, exceeded the EPA's drinking water standard of 15 pCi per liter ( 1 8 . 2 pCi per liter in 1983 and 20.5 pCi per liter in 1984). On May 7 and 8, 1986, Oak Ridge Associated Universities (ORAU) personnel took water samples from 44 perimeter wells;.only one (by Old St. Charles Rock Road) with 17 pCi alpha activity per liter exceeded the drinking water standard.2
The operators of the landfill, West Lake Landfill, Inc., have an ongoing hydrogeologic investigation of the site, which also involves analyses of monitoring well samples for radioactivity and for priority pollutants.^
4 ESTIMATION OF RADIOACTIVITY INVENTORY i

Soil sample analyses have shown that the radioactive material in Areas 1 and 2 of the landfill consists almost entirely of natural uranium and its radioactive decay products.
The analyses of soil samples indicate that the naturally occurring U-238 to Th-230 to Ra-226 equilibrium has been altered and that the ratio of Ra-226 to U-238 is on the order of 2:1 to 10:1; the ratio of Th-230 to Ra-226 generally ranges from 4:1 to about 40:1. These ratios are in accord with the history of the radionuclide deposits in the West Lake Landfill, i.e., that they came from the processing of uranium ores. The indicator radionuclides for assessment of the radiological impacts of the material are therefore U-238, Th-230, and Ra-226. Using the RMC data and averaging the auger hole measurements over the volumes of radioactive material found in Areas 1 and 2, a mean concentration of 90 pCi per gram 3 was calculated for Ra-226.2 For the ratio of Th-230 to Ra-226, the RMC data range from 4:1 to 40:1; data from samples taken in 1984 along the term range up to almost 70:I.5 A further consideration is that the material came from Cotter Corporation's Latty Avenue site (later sold to Futura Coatings, Inc.). Measurements at the Latty Avenue site are variously reported as up to 180:I6 and about 300:I.7 Some material of that nature might have been transferred along with the barium sulfate residues. To ensure conservatism in estimating the long-term in-growth of Ra-226, the NRC staff used a ratio of 100:1 to estimate the Th-230 activity. Similarly, the Ra-226:U-238 ratio ranges from 2:1 to 10:1. This ratio is less critical to the radiological aspect of the site and has been estimated to be 5:1 for purposes of calculation.

Using the Th-230:Ra-226 ratio of 100:1, the Th-230 activity is 9000 pCi per gram. If the U-238 concentration (as well as U-234 which would be similarly separated from the ore) is a factor of 5 less than Ra-226, this implies about 18 pCi U-238 per gram. The total mass of radioactive material in the landfill was estimated by visually integrating the volume of radioactive material from graphs and multiplying by an average soil density, resulting in 1.5 x 1011 grams (150,000 metric tons) of contaminated soil.

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These numbers indicate that there are about 14 Ci of Ra-226 contained with its decay products in the radioactive material in the landfill. The material also contains about 3 Ci each of U-238 and U-234, and about 1400 Ci of Th-230. These estimates indicate the order of magnitude of the quantities to be dealt with, although the estimate for Th-230 is regarded as conservatively large.
5 APPLICABILITY OF THE BRANCH TECHNICAL POSITION

Based on EPA uranium mill tailings cleanup standards. Concentrations based on limiting individual doses to 170 mrem per year. Concentration based on limiting equivalent exposure to 0.02 WL or less. Concentrations based on limiting individual intruder doses to 500 mrem per year and, in cases of natural uranium, limiting exposure to Rn-222 and other airborne alpha emitters to 0.02 WL or less. Options 1-4 provide methods under 10 CFR 20.302, for onsite disposal of slightly contaminated materials, e.g., soil, if the concentrations of radioactivity are small enough and other circumstances are satisfactory. The fifth option consists of onsite storage pending availability of an appropriate disposal method.
The material present in the West Lake Landfill is a form of natural uranium with daughters, although the daughters are not now in equilibrium. As mentioned in

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Section 4, the average concentration of Ra-226 in the West Lake Landfill wastes is about 90 pCi per gram, which (considered by itself) falls into Option 4 of the BTP since Option 4 criteria are controlled by the Ra-226 content in the wastes (i.e.,200 pCi of U-238 plus U-234 per gram would be accompanied by 100 pCi of Ra-226 per gram). However, because of the large ratio of Th-230 radioactivity,to that of Ra-226, the radioactive decay of the Th-230 will increase the concentration of its decay product Ra-226 until these two radionuclides are again in equilibrium. Assuming the ratio of activities of 100:1 used above, the Ra-226 activity will increase by a factor of five over the next 100 years, by a factor of nine 200 years from now, and by a factor of thirtyfive 1000 years from now. All radionuclides in the decay chain after Ra-226 (and thus the Rn-222 gas flux) will also be increased by similar multiples. Therefore, the long-term Ra-226 concentration will exceed the Option 4 criteria. Under these conditions, onsite disposal, if possible, will likely require moving the material to a carefully designed and constructed "disposal cell."
6 REMEDIAL ACTION ALTERNATIVES EXAMINED

The evaluation performed by staff of the University of Missouri at Columbia addresses six potential remedial action alternatives, including that of leaving the radioactive material as it is, designated Option A.2 Option D is the option of excavating the material and shipping it to another site for disposal. Options B, C, E, and F address different approaches to stabilizing the material on the West Lake Landfill site, "primarily as temporary remedial actions. Options B, C, and F leave most of the radioactive material where it is but include a variety of measures to contain it and its radon releases and gamma emissions. Option E addresses the approach of constructing an onsite earthen cell, similar to a disposal cell, and moving the radioactive material into it. Under Option F, the radioactive material would be left in place and separate slurry walls would be built downgradient of Areas 1 and 2 to constrain groundwater motion. The estimated costs of Options B through F range from about $370,000 (Option B) to about $5,500,000 (Option F) in 1984 dollars. The estimate for Option D is about $2,500,000, but this does not include the cost of transporting the material to another site and disposing of it there; in the staff's judgment, this could increase the cost by as much as a factor of ten.

Further studies are necessary to determine the most practical approach to disposal of this material.
7 FACTORS CONTRIBUTING UNCERTAINTY

The presence in the landfill of other substances listed as hazardous by the U.S. Environmental Protection Agency raises issues of whether the waste is mixed waste (i.e., both radioactive and chemically hazardous), and whether the landfill must also be disturbed to provide for proper containment of the chemical wastes.

The manner of placing the 43,000 tons of contaminated soil in the landfill caused it to be mixed with additional soil and other material, so that now an appreciably larger amount is involved. If it must be moved, it is not certain whether the amount requiring disposal elsewhere is as little as 60,000 tons or even more than 150,000 tons.

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Because the controlling radionuclide (Th-230) has no characteristics that make it easy to measure quantitatively in place, as can be done for the Ra-226 with its decay products, the large but variable ratio of Th-230 to Ra-226 and its decay products makes the delineation of cleanup more difficult. When the ratio is so large (20:1 or more), even a small concentration of Ra-226 in 1988 implies such a large concentration later that it will be necessary to employ more difficult measurement techniques to confirm that the cleanup has been satisfactory. Any possibility of disposal on site will depend on adequate isolation of the waste from the environment, especially for protection of the groundwater. It is unclear whether the area's groundwater can be protected from onsite disposal at a reasonable cost. This matter will require additional investigation.
8 SUMMARY

In 1973, radioactively contaminated soil amounting to approximately 43,000 tons was deposited,'in the West Lake Landfill near St. Louis, Missouri. The material originated with decontamination efforts at the Cotter Corporation's Latty Avenue plant. Disposal in the West Lake Landfill was not authorized by the NRC. State officials were not notified of this disposal in 1973 because the landfill was not regulated1by the State at the time.
In the period 1980-1981, Radiation Management Corporation (RMC) of Chicago, Illinois, under contract to the NRC, performed a detailed radiological survey of the West Lake Landfill. This survey showed that the radioactive contaminants are in two areas. The northern area (Area 2) covers about 13 acres. The radioactive debris forms a layer 2 to 15 feet thick, exposed in only a small area on the landfill surface and along the bertn on the northwest face of the landfill. The southern area (Area 1) contains a relatively minor fraction of the debris covering approximately 3 acres with most of the contaminated soil buried with about 3 feet of clean soil and sanitary fill.
The RMC survey showed that the radioactivity is from the naturally occurring U-238 and U-235 series with Th-230 and Ra-226 as the radionuclides that dominate radiological impact. The survey data indicate that the average Ra-226 concentration;in the radioactive wastes is about 90 pCi per gram; the staff estimates the average Th-230 concentration to be about 9000 pCi per gram. Since Ra-226 has been depleted with respect to its parent Th-230, Ra-226 activity will increase in time (for example, over the next 200 years, Ra-226 activity will increase ninefold over the present level). This increase in

Ra-226 must be considered in evaluating the long-term hazard posed by this radioactive material.
In addition to RMC's radiological survey, soil and water samples were collected and analyzed by others, including ORAU, UMC, and MDNR. Occasionally a sample of water from a monitoring well exceeds slightly the ERA drinking water standard of 15 pCi gross alpha per liter. Sample analyses for priority pollutants (nonradioactive hazardous substances) show a number of listed pollutants are present. The landfill operators are also conducting a hydrogeological investigation.
From the RMC, UMC, and ORAU surveys conducted at the West Lake Landfill site the staff has made the following findings:

14

(1)

There Is a large quantity (on the order of 150,000 tons) of soil contaminated with long-lived radioactive material in the West Lake Landfill. Almost all the radioactivity consists of natural uranium and its radioactive decay products.3 Based on the radiological surveys, the radioactive wastes as presently stored at the West Lake Landfill do not satisfy the conditions for Options: 1-4 of the NRC's Branch Technical Position (BTP) regarding the disposal of radioactive wastes containing uranium or thorium residues.8

(2)

(3) A dominant factor for the future is that the average activity concentration of Th-230 is much larger than that of its decay product Ra-226, indicating a significant increase in the radiological hazards in the years and centuries to come.
(4) Some of the radioactive material on the northwestern face of the berm has no protective cover of soil to prevent the spread of contamination and attenuate radiation.

(5) Slightly more than 8 acres of the site exceed 20 uR per hour; the highest reading of 1600 uR per hour occurs near the Butler-type building.

(6)
(7)

Radon and daughters were measured at 0,031 WL in and around the Butler-type building. This exceeds the BTP value of 0.02 WL.
Based on monitoring-we11 sample analyses, some low-level contamination of the groundwater is occurring, indicating that the groundwater in the vicinity is not adequately protected by the present disposition of the wastes. *

(8)

Although these radiological conditions indicate that remedial action is needed, it is unlikely that anyone has received significant radiation exposures from the existing situation.

(9)

Sampling results show that chemically hazardous materials have been disposed of adjacent to or possibly mixed with the radioactive material.3 It is possible that part of the radioactive material has become "mixed" waste.

From these findings and the information developed to date, the NRC staff concludes: (1) measures must be taken to establish adequate permanent control of the radioactive waste and to mitigate the potential long-term adverse impacts from its existing temporary storage conditions and (2) the information developed to date is inadequate for a technological determination of several important issues, i.e., whether mixed wastes are involved, and whether onsite disposal is practical technologically, and, if so, under what alternative methods. As indicated by the estimates developed by UMC, remedial action will be costly. Further, the investigations to develop the necessary information to resolve major questions and to provide a sound basis for evaluation of the feasibility of disposal alternatives may also be costly. Therefore, it is necessary to determine the way to accomplish the further studies and remedial actions that are needed.

The West Lake Landfill is located near the city of St. Louis in Bridgeton, St. Louis County, Missouri. The site has been used since 1962 for disposing of municipal refuse, industrial solid and liquid wastes, and construction demolition debris. This report summarizes the circumstances of the radioactive material in the West Lake Landfill. The radioactive material resulted from the processing of uranium ores and the subsequent sale by the Atomic Energy Commission .of the processing residues. Primary emphasis is on the radiological environmental aspects as they relate to potential disposition of the material. It is concluded that remedial action is called for.

PREFACE
This report has as its basis a characterization of the West Lake Landfill site and evaluation of some potential remedial measures performed primarily by S. K. Banerji, W. H. Miller, J. T. O'Connor and L. S. Uhazy of the University of Missouri-Columbia. The Nuclear Regulatory Commission received the first and second drafts,1 then titled "Engineering Evaluation of Options for Disposition of Radioactively Contaminated Residues Presently in the West Lake Landfill, St. Louis County, Missouri," in 1984; thus most of the information in this report dates from 1983-1984. However, some more recent data, principally water sampling results, have been added. Waste disposal and other industrial activities have continued on the 200 acre site, as have activities in the vicinity, resulting in changes in details of topography, roads, etc. To provide a more complete view of the radioactive material in the landfill, use has been made of figures from the report titled "Radiological Survey of the West Lake Landfill, St. Louis County, Missouri," NUREG/CR-2722, May 1982.

The remedial action concepts in this report are those proposed by the contractor. Judgments expressed in this report about these concepts are in general those of i the contractor, and do not necessarily represent the views of the Nuclear Regulatory Commission. For example, the cost estimates for these concepts are based on radium-226 concentrations whereas the long-term issue is dependent upon the thorium-230 concentrations. Although some of its information has not been updated since 1984, this report is being released so as to make its collected information available to interested parties.

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ABSTRACT i

The West Lake Landfill is near the city of St. Louis in Bridgeton, St. Louis County, Missouri. In addition to municipal refuse, industrial wastes and demolition debris, about 43,000 tons of soil contaminated with uranium and its radioactive decay products were placed there in 1973. After learning of the radioactive material in the landfill, the U.S. Nuclear Regulatory Commission (MRC) had a survey of the site's radioactivity performed and, 4n 1983, contracted, through Oak Ridge Associated Universities (ORAU), with the University of MissouriColumbia (UMC)lto characterize the environment of the site, conduct an engineering evaluation; and propose remedial measures. This report presents a description of the results of the UMC work, providing the environmental characteristics of the site, the extent and characteristics of the radioactive material there, some considerations with regard to potential disposal of the material, and some concepts for remedial measures.

Location of West Lake Landfill......................... Land use around West Lake Landfill site................ Zoning plan of West Lake area (June 1984).............. Site topography and extent of contamination............ Bedrock stratigraphy................................... Location of monitoring wells........................... Soil profile of river alluvium......................... Cross-section of Missouri River alluvial valley ....... Soijl profile of upland loessal soil.................... Surface hydrology of West Lake area.................... Average monthly precipitation at Lambert Field International Airport.................................. Wind distribution for West Lake area................... External gamma radiation levels (November 1980)........ Location of surface soil samples, Area 1............... Location of surface soil samples, Area 2............... Location of auger holes, Area I........................ Location of auger holes, Area 2........................ Auger hole elevations and location of contamination within each hole....................................... Cross-section B-B showing subsurface deposits in Area 1................................................. Cross-section E-E showing subsurface deposits in Area 2................................................. Rn-222 flux measurements at three locations in Area 2 (1981).................................................
TABLES

RMC radionuclide analyses of water samples from the West Lake site taken by MDNR in 1981................... Radiological quality of water in perimeter monitoring wells of West Lake Landfill (concentrations reported in pCi/1).............................................. Radionuclide concentrations in well water samples: May 7-8, 1986.......................................... Radionuclide concentrations in Latty Avenue composite samples................................................

In 1973, approximately 7900 metric tons (mt) (8700 short tons) of radioactive!./ contaminated barium sulfate (BaS04) residues were mixed with about 35,000 mt (39,000 t) of soil, and the entire volume was placed in the West Lake Landfill in St. Louis County, Missouri. This material resulted from decontamination efforts at the Cotter Corporation's. Latty Avenue plant where the material had been stored. Disposal in the West Lake Landfill was not authorized by the Nuclear Regulatory Commission (NRC) and was contrary to the disposal location indicated in the NRC records. State officials were not notified of this disposal since the landfill was not regulated by the State at the time. Although the contamination does not present an immediate health hazard, authorities have been concerned about whether this material poses a long-term health hazard to workers and residents of the area and what, if any, remedial action is necessary. In 1980-81, Radiation Management Corporation (RMC) of Chicago, Illinois, performed a detailed radiological survey of the West Lake Landfill under contract to the NRC (NUREG/CR-2722). This survey was performed to determine the extent of radiological contamination. Before this survey, little was known about the location or activity of radionuclide-bearing soils in the landfill. This survey showed that the radioactive contaminants are in two areas. The • northern area (Area 2) covers about 13 acres. The radioactive debris forms a layer 2 to 15 feet thick, exposed in only a small area on the landfill surface and along the berm on the northwest face of the landfill. The southern area (Area 1) contains a relatively minor fraction of the debris covering approximately 3 acres with most of the contaminated soil buried with about 3 feet of clean soil and sanitary fill.

The RMC survey showed that the radioactivity is from the naturally occurring U-238 and U-235 series with Th-230 and Ra-226 as the radionuclides that dominate radiological impact. The survey data indicate that the average Ra-226 concentration in the radioactive wastes is about 90 pCi per gram; the average Th-230

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concentration is estimated to be about 9000 pCi per gram. Since Ra-226 has been depleted with respect to its parent Th-230, Ra-226 activity will increase in time (for ;example, over the next 200 years, Ra-226 activity will increase ninefold over the present level). This increase in Ra-226 must be considered in evaluating the long-term hazard posed by this radioactive material.

In addition to RMC's radiological survey, toil «nd water samples were collected and analyzed by others, including Oak Ridge Associated Universities (ORAU), and the University of Missouri-Columbia (UMC). "Occasionally a cample of water from •a monitoring well exceeds slightly the EPA drinking water standard of 15 pCi gross alpha per liter. Sample analyses for priority pollutants (non-radioactive hazardous substances) show a number of listed pollutants are present.
i
On the basis i of radiological surveillance conducted by RHC, UMC, and ORAU, the following areas of concern have been identified: (1) Radioactive soil is eroding from the northwestern face of the berm, and is being transported off site.
Radon gas had been observed to accumulate to an unacceptable level in the Butler-type building on site. This building has since been removed.

(2)

(3)

Some degree of radiological contamination has been found in the wells that monitor the perimeter.
Surface exposure rates over much of the contaminated areas are greater than 20 uR/hr.

(4)

In March 1983, the NRC through ORAU, contracted with UMC to conduct an engineering evaluation of the site and propose possible remedial measures for NRC's consideration for dealing with the radioactive waste at the West Lake Landfill. The following six remedial options were proposed and «valuated in this study.

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Option A - No remedial action Option B - Stabilization onsite with restricted land use

I I I I I I I I I I I I I I I I I I I

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Option C - Extending the landfill offsite with restricted land use Option D - Removal and relocation of the contaminated material to an authorized disposal site Option E - Excavation and temporary onsite storage in a trench Option F - Construction of a slurry wall to prevent leachate from migrating off site

It is noted that some of the above alternatives for remedial action were initially evaluated with the objective of permanent disposal of the waste at the site.

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1 INTRODUCTION

The West Lake Landfill is located in St. Louis County, Missouri, 6 km (3.7 miles) west of Lambert Field International Airport (Figure 1.1) and southwest of St. Charles Rock Road in Bridgeton, Missouri. The site has been used since 1962 for disposing of municipal refuse, industrial solid and liquid wastes, and construction demolition debris. In addition, the landfill is an active Industrial complex on which concrete ingredients are measured and combined before mixing ("batching"), and asphalt aggregate is prepared. Limestone ceased to be quarried in the spring of 1987.

In 1973, 7900 metric tons [(mt) (8700 short tons)] of radioactively contaminated barium sulfate (BaS04) residues from uranium and radium processing were mixed with an estimated 35,000 mt (39,000 tons) of soil and deposited in the West Lake Landfill. Previously, this material was located at the Cotter .Corporation's Latty Avenue facility in Hazelwood, Missouri, and was removed during decontamination work. It is not known what levels of contamination were already in the soil before the barium sulfate residues were mixed into it. Disposal in the West Lake Landfill was unauthorized and contrary to the disposal location indicated in the U.S. Nuclear Regulatory Commission's (NRC's) records.
Subsequently, the NRC sponsored studies that were directed at determining the radiological status of the landfill. In 1978, an aerial radiological survey revealed two areas within the landfill where the gamma radiation levels indicated radioactive material had been deposited. A Bore extensive survey was initiated in November 1980 by the Radiation Management Corporation (RMC) under contract to the NRC.
In March 1983, the NRC through Oak Ridge Associated Universities (ORAU) contracted with the University of Missouri-Columbia Department of Civil Engineering to describe the environmental characteristics of the site, conduct an engineering evaluation, and propose possible remedial measures for dealing with the radioactive waste at the West Lake Landfill. In May 1986, ORAU sampled water from

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wells on and close to the, landfill to determine if the radioactive migrated into the groundwater.
Information from;*!! these sources forms the basis for this report.

This chapter presents a historical and environmental description of the West Lake Landfill site located in St. Louis County, Missouri.
2.1 Location
I The 81-hectare (ha) (200-acre) West. Lake Landfill property is situated between the St. Charles Rock Road and the Old St. Charles Rock Road in Bridgeton, Missouri. The southeastern and northwestern parts of the landfill abut farmland. Several commercial and industrial facilities are located near the landfill (Figure 2.1). The nearest residential area is a trailer park located approximately 1 km ( 0 . 6 mile) to the southeast. A major portion of the landfill (roughly the northern three-fourths of the site) is located on the floodplain, approximately 2 km (1.2 miles) from the Missouri River.

The zoning plan obtained from the Bridgeton Planning and Zoning Department for properties on and adjacent to the landfill is shown in Figure 2.2. A portion of the landfill, including site Area 1, is zoned M-l, which is designated for light manufacturing; the northwest part of the landfill, including Area 2, is zoned as single-family residential (R-l). This R-l zoning indicates the use to which the land was originally intended. However, the landfill was extended over the land zoned R-l, and the zoning plan was simply not changed to reflect the new usage. Other discrepancies between land use and zoning are found in the nearby Earth City Industrial Park (William Canney, Safety Supervisor of West Lake Landfill, Inc., personal communication, March 1984). The land across St. Charles Rock Road is zoned for light and heavy manufacturing. The remainder of the property surrounding the landfill is zoned residential and business.

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2.3 History

The West Lake Landfill was started In 1962 for the disposal of municipal and industrial solid wastes, and to fill in the excavated pits from the quarry operations that had been performed at the site since 1939 (Canney, personal communication, March 1984). In 1974, the landfill was closed by the Missouri Department of Natural Resources (MDNR) (Karen, 1976). A new sanitary landfill, in an area of the West Lake Landfill property which is protected from groundwater contact, now operates under an MDNR permit.

This new part of the landfill was opened in 1974. The bottom is lined with clay and a leachate collection system has been installed. Leachate is pumped to a treatment system consisting of a lime precipitation unit followed in series by an aerated lagoon and two unaerated lagoons. The final lagoon effluent is discharged into St. Louis Metropolitan Sewer District sewers. The quarrying operation ceased in the spring of 1987 because not enough "good rock" was left at the site.
2.4 Ownership

The West Lake Landfill was owned from 1939 until 1988 by West Lake Landfill, Inc., of 13570 St. Charles Rock Road, Bridgeton, Missouri. Most of the landfill was sold in 1988 to Laidlaw Industries, Inc. The two areas which contain the radioactive material were retained by West Lake Properties as the principal properties of a subsidiary named Rock Road Industries, Inc.
2.5 Contaminated Areas

Radioactive contamination at the West Lake Landfill has been identified in two separate soil bodies (Figure 2.3). Comparisons of radionuclide quantities and of the activity ratios between radionuclides not in secular equilibrium, indicate that the radioactive contamination in the separate soil bodies was derived from the same source, i.e., the Cotter Corporation's former Latty Avenue facility in Hazelwood, Missouri (NRC, NUREG/CR-2722).

2-2

The northern area (referred to as Area 2) of contamination shown on Figure 2.3 4* covers an area of 5.2 ha (13 acres) and lies above 5 to 6 m (16-20 ft) of landfill debris. The contaminated soil forms a more or less continuous layer from 1 to 4 m (3 to 13 ft) in thickness, and amounts to approximately 100,000 m3 (130,000 yd3). Some of this contaminated soil is near or at the surface, particularly along the face of the northwestern berm. Beneath the landfill debris, the soil profile consists of 1 to 2 m (3 to 7 ft) of floodplain top soil overlying 10 to 15 m (33 to 50 ft) of sand and gravel alluvium. The southern area of contamination (referred to as Area 1) shown on Figure 2.3 covers approximately 1.1 ha (3 acres) and contains roughly 15,000 m3 (20,000 yd3) of contaminated soil. This body of soil is located east of the landfill's main office at a depth of about 1 m (3 to 5 ft), and is located over a former quarry;pit, which was filled in with debris. The depth of debris beneath the contaminated soil is unknown, but is estimated to be 15 to 20 m (50 to 65 ft). Limestone bedrock underlies the landfill debris.
2.6 Topography

About 75% of the landfill site is located on the floodplain of the Missouri River. The site topography is subject to change because of the types of activities (e.g., landfilling and quarrying) performed there. Figure 2.3 shows a contour map of the site as of July 1986. The surface runoff follows several surface drainsi and ditches which run in a northwest direction and drain into the Missouri River.
2.7 Geology

2.7.1

Bedrock

Bedrock beneath the West Lake Landfill consists of Mississippi an age limestone of the Heramacean Series of the St. Louis and Salem formations, which extends downward to an elevation of 58 m ( 1 9 0 ft) mean sea level (msl) (Figure 2.4).*

The limestone is dense, bedded, and fairly pure except for intermittent layers which consist of abundant chert nodules. The Warsaw formation—also of Mississippian age—lies directly beneath the limestone. The Warsaw is made up of approximately 12 ra (38 ft) of slightly calcareous, dense shale; this grades into shaley limestone toward the middle of the formation (Figure 2.4) (Spreng, 1961). Bedrock beneath the site dips at an angle of 0.5° to the northeast. Eight kilometers (5 miles) east of the site, the attitude of the bedrock is reversed by the Florissant Dome; the bedrock dips radially outward from the apex of this dome at a low angle (Martin, 1966).

Since karst (solution) activity often occurs in carbonate rocks, the possibility of its occurrence in the West Lake Landfill area was considered. Brief observation of the quarry walls at the landfill suggests that some solution of the limestone has occurred, but this solution activity has apparently been limited (see Section 2.8.1) to minor widening of joints and bedding planes near the bedrock surface. Although karst activity within the limestone is relatively minor, the upper surface of the bedrock is irregular and pitted as a result of solution (Lutzen and Rockaway, 1971). This alteration of the bedrock surface is greatest beneath the Missouri River floodplain.
2.7.2 Soils

Soil material in this area may be divided into two categories: Missouri River alluvium and upland loessal soil. This demarcation is shown as the historical edge of the alluvial valley in Figure 2.5. The division is made on the basis of soil composition, depositional history, and physical properties. Because the West Lake Landfill lies over this transition zone, the surface material at the site varies considerably from southeast to northwest. The Missouri River alluvium (Figure 2.6) ranges in thickness from 12 m (40 ft) beneath the landfill site to more than 30 m ( 1 0 0 ft) at mid-valley (Figure 2 . 7 ) . The upper 3 m (10 ft) of the soil profile consists of organic silts and clays, that have been deposited by the Missouri River during floods.* Below this

surface layer, the soil becomes sandy and grades to gravel at depths greater than 5 to 10 m (16 to 33 ft). Because of the effects of channel scour, which continues to grade the sediment after its initial deposition, the alluvium is fairly homogeneous in a .horizontal direction and becomes progressively coarser with depth (Gobdfield, 1965). At the edges of the floodplain, the alluvium is not as well graded, and a large amount of fine material is present in the deeper sand and gravel.

The upland loessal soil (Figure 2.8) is generally thinner than the floodplain soil, being usually less than 12 m (39 ft) thick, and was deposited during the age of Pleistocene glaciation. The:loess consists of silt-sized particles that were transported by wind and deposited as a blanket over much of Missouri and Illinois. On the hills near the West Lake Landfill, the loess layer may be as much as 24 m (79 ft) thick. It consists of 6 to 9 m (20 to 30 ft) of fairly pure silt (Peo'ria loess) overlying 6 to 15 m (20 to 49 ft) of clay silt (Roxana loess) (Lutzen and Rockaway, 1971). This loess forms the hills to the southeast of the landfill, but it has long ago been removed from the landfill site and most of the surrounding valleys by erosion. The upper 1 m (3 ft) of the loess has been altered to form a thin soil profile. It should be noted that loess has a vertical permeability which is far greater than its horizontal permeability (Freeze and Cherry, 1979). The total permeability of loess is greatly increased by disturbance. The individual silt grains are generally quite angular, and therefore may ;not be effectively compacted by the methods commonly used to consolidate clay. The technique most effective in the compaction of loess would employ vibration beneath a surcharge. A relict soil profile from 5 to 10 m (16 to 33 ft) thick lies beneath the loess and directly on top of the bedrock. This soil was formed as a residuum before Pleistocene glaciation and was subsequently covered by the loess blanket. This soil is a highly consolidated clay containing abundant chert fragments (Lutzen and Rockaway, 1971). In addition to the natural geologic properties of the landfill, human disturbance of the soil must also be considered since material within the landfill itself can either limit or facilitate migration of leachate to the Missouri River alluvial aquifer.

In order to prevent downward movement of leachate, it is now a common practice to place a layer of compacted clay beneath sanitary landfills. Newer portions
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of the landfill (constructed since 1974) have 2 to 3 m (7 to 10 ft) of clay at the base and around the sides. Waste is covered every day with 15 cm (6 in.) of compacted soil; the cover soil presently used is loess (of soil classifications CL and A4) taken from southeast of the landfill (Reitz and Jens, 1983a). If not properly compacted, this material may have a permeability of 0.0001 cm/sec (0.00004 in./sec) or more. It is not known what procedures for compaction, if any, were used at the landfill before 1974 since the site was unregulated in design as well as in materials which were accepted for disposal. 4t Is believed, however, that there is no liner present beneath the northwestern portion of the landfill, and that sanitary (and, possibly, some hazardous) material was placed directly on the original ground surface. Since waste was periodically covered with soil to minimize rodent and odor problems, the landfill probably consists of discrete layers of waste separated by thin soil layers. Both areas containing radioactive material are in these presumably unlined g^ above-ground portions of the landfill.
2.8 Hydrology

2.8.1

Subsurface Hydrology I

Groundwater flow in the area surrounding the West Lake site is through two aquifers: the Missouri River alluvium and the shallow limestone bedrock. The base of the limestone aquifer is formed by the relatively impermeable Warsaw
shale at an elevation of about 58 m (190 ft) msl (Figure 2.4). This shale

layer has been reached, but not disturbed, by quarrying operations. Therefore, the Warsaw shale acts as an aquiclude, making contamination of the deeper limestone very unlikely. The Mississippi an limestone beds have very low intergranular permeability in an undisturbed state (Miller, 1977). However, a strong leachate enters the quarry pit at an elevation of about 67 m (220 ft) msl (pt. A on Figure 2.5). This leachate is migrating vertically through more than 30 m (98 ft) of limestone. Explosive detonations associated with quarrying operations will tend to cause fractures to propagate in the quarry wall. These fractures have probably extended less than 10 m (33 ft) into the rock from the quarry face. Beyond this, the rock probably remains undisturbed. These fractures will tend to increase inflow to the quarry pit and allow leachate to percolate downward through the fractured zone. Thus, leachate inflow to the
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quarry pit Is not evidence of large-scale contamination of the limestone aquifer. The^nly other mechanism by which leachate could travel rapidly through the limestone is by transport through solution channels. ' Landfill consultants and quarry operators maintain that the limestone is fairly intact (Canney, personal communication, September 1983), and superficial observation of the quarry walls seems to support this conclusion. Since the limestone is fairly impervious, and groundwater flows in most areas from the bedrock into *, the alluvium, contamination of water in the bedrock aquifer does not appear likely. The water table of the Missouri River floodplain is generally within 3 m (10 ft) of the ground|surface, but at many points it is even shallower. At any one time, the water levels and flow directions are influenced by both the river stage and the amount of water entering the floodplain from adjacent upland areas. A high river stage tends to shift the groundwater gradient to the north, in a direction that more closely parallels the Missouri River. Local rainfall will !shift the groundwater gradient to the west, toward the river and along the fall of the ground surface. This is inferred from water levels measured in monitoring wells at the West Lake site. The fact that groundwater levels commonly fluctuate more than does the Missouri River level, indicates that upland-derived recharge exerts a great deal of influence over groundwater flow at the West Lake site. This influence decreases toward the river. The deep Missouri River alluvium acts as a single aquifer of very high permeability. This aquifer is relatively homogeneous in a downstream direction, and decreases in permeability near the valley walls. The deeper alluvium is covered by 2 to 4 m (7 to 13 ft) of organic silts and clays that may locally contain a large fraction of sand-sized particles. Water levels recorded between November 1983 and March 1984 in monitoring wells at West Lake9" indicate a groundwater gradient of 0.005 flowing in a N 30°W direction beneath the northern portion of the landfill. This represents the likely direction of any possible leachate migration from the landfill (Figure 2.5).

*Data supplied by Reitz and Jens engineering firm, St.Louis, 1984.

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The alluvial aquifer recharges from upland areas from three sources: seepage from loess and bedrock bordering the valley, channel underflow of upland streams entering the valley, and seepage losses from streams as they cross the floodplain. Of these sources, streams and their underflow represent the main source of upland recharge to the alluvial aquifer. Streams entering the floodplain raise the water table in a fan-shaped pattern radiating outward from their point of entrance to the plain. In areas where streams are not present, the water slopes downward from the hills, steeply at first and then gently to the level i of the free water surface in the Missouri River channel. The situations described above do not take into account the effect of variations in permeability of the shallow • i soil layer. Aerial photography of the site indicates that a filled backchannel (oxbow lake) type of soil deposit is present along the southwest boundary of the landfill (USDA, 1953). This deposit is probably composed of fine-grained material to the depth of the former channel (6 to 10 m) (20 to 33 ft). This deposit may tend to hamper communication between shallow groundwater on opposite sides of the deposit. Since no other recharge sources exist above the level of the floodplain, the only water available to leach the landfill debris is that resulting from rainfall infiltrating the landfill surface. Because the underlying alluvral aquifer is highly permeable, there will be little "mounding" of water beneath the landfill. Because the northern portion of the landfill has a level surface it is likely that at least half of the rainfall infiltrates the surface. The remaining rainfall is lost to evapotranspiration and (to a lesser degree) surface runoff. Due to the height of the berm, temporary impoundment of surface runoff is a common occurrence. No public water supplies are drawn from the alluvial aquifer near the West Lake Landfill. It is believed that only one private well (Figure 2.9) in the vicinity of the landfill is used as a drinking water supply. This well is 2.2 km (1.4 miles) N 35°W of the former Butler-type Building location on the West Lake Landfill. In 1981, analysis showed water in this well to be fairly hard (natural origins) but otherwise of good quality (Long, 1981).

Water in the Missouri River alluvium is hard and usually contains a high concentration of iron and manganese (Miller, 1977). The amount of dissolved
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solids present in the water of the alluvial aquifer varies greatly; purity increases toward mid-valley where groundwater velocity is greatest. A water sample from a well in the alluvium 3 km ( 1 . 9 miles) north of the landfill had a total dissolved solids content of 510 mg/liter and total hardness as CaC03 of 415 ing/liter. Water in the limestone bedrock generally has a hardness greater than 180 mg/liter as CaC03 equivalent (Emmett and Jeffery, 1968). Total dissolved solids range from 311 to 970 mg/liter. Water in the limestone aquifer may contain a large amount of sulfate of natural origin (Miller, 1977). 2.8.2 Surface Hydrology
l

Because of the extremely low slope of the Missouri River flood plain surface, precipitation 'falling on the plain itself generally infiltrates the soil rather than running off the surface. The only streams present on the floodplain are those that originate in upland areas. Drainage patterns on the plain (Figure 2.9) have been radically altered by flood control measures taken to protect Earth City (Figure 2.1) and by drainage of swamps and marshes. Before these alterations, Creve Coeur Creek passed just south of the landfill, and drained a fairly large area. It has since been redirected to discharge into the Missouri River upstream (south) of St. Charles (Figure 2.9). The'old channel still carries some water, and empties into the Missouri River 45.2 km (28 miles) upstream from the confluence with the Mississippi River. Near the landfill, this stream is usually dry. As it crosses the flood plain, the creek passes through shallow lakes which provide a more or less continuous flow to the Missouri River throughout the year. A second stream, Cowmire Creek, crosses the floodplain east of the site. This stream flows northward and joins a backwater portion of the Missouri River at kilometer 35.4 (22 miles). Because of the relationship which exists between river level and groundwater level in portions of the floodplain near the river, these streams may either lose flow (at low stage) or gain flow (at high stage). The present channel of the Missouri River lies about 3 km (2 miles) west and northwest of the landfill. Early land surveys of this area indicate that 200 years ago the channel was located several hundred meters to the east (toward the landfill) of its present course (Reitz and Jens, 1983b). The Missouri River has a surface slope of about 0.00018 (Long, 1981). River stage at St. Charles

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[kilometer 45.2 (mile 2 8 ) ] is zero for a water level of 126.1 m (413.7 ft) msl (Reitz and Jens, 1983a). Average discharge of the Missouri River is 2190 mVs (77,300 ftVs), with a maximum flow of 2850 mVs (101,000 ftVs) for the period of April through July, and a minimum flow of 1140 m3/s (40,300 ftVs) in January and December (Miller, 1977). Some average properties of Missouri River water for the period 1951-1970 were: alkalinity = 150 mg/liter as CaC03 equivalent; hardness = 209 mg/liter as CaC03 equivalent; pH = 8.1; and turbidity = 694 JTU (Jackson turbidity unit). Water supplies are drawn from the Missouri River at kilometer 46.6 (mile 29) for the city of St. Charles, and the intake is located on the north bank of the river. Another intake at kilometer 33 (mile 20.5) is for the St. Louis Water Company's North County plant (Reitz and Jens, 1983a).

The city of St. Louis takes water from the Mississippi -River, which joins the Missouri River downstream from the landfill. In this segment of the river, the two flow-streams have not completely mixed and the water derived from the Missouri River is still flowing as a stream along the west bank of the Mississippi River channel*. The intake structures for St. Louis are on the east bank of the river so that the water drawn is derived from the upper Mississippi.
2.9 Meteorology

The climate of the West Lake area is typical of the midwestern United States, in that there are four distinct seasons. Winters are generally not too severe and summers are hot with high humidity. First frosts usually occur in October; and freezing temperatures generally do not persist past March. Rainfall is : greatest in the warmer months, (about one-quarter of the annual precipitation occurs in May and June) (Figure 2.10) (NRC, 1981). In July and August, thunderstorms are common, and are often accompanied by short periods of heavy rainfall. Average annual precipitation is 897 mm (35.3 in.), which includes the average annual snowfall of 437 mm (17.2 inches snow). Average relative humidity is 68%,

*Ned Harvey, 'hydrologist with the USGS, telephone communication, August 1983.

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and humidities over 80% are common during the summer. Wind during the period of December through April is generally from the northwest; winds blow mainly from the south throughout the remainder of the year. A compilation of hourly wind observations shows that although the wind resultant is fairly consistent on a monthly basis, the wind actually shifts a good deal and is very well distributed in all directions (Figure 2.11) (NRC, 1981; U.S. Department of Commerce, 1960). Meteorological data used is from Lambert Field International Airport which is 6 km (3.7 miles) east of the West Lake site. Temperature and precipitation data are also representative of West Lake. However, because of differences in topography between Lambert Field and the site, the actual wind directions at West Lake may be slightly skewed in a NE-SW direction parallel to the Missouri River valley.
2.10 Ecology
I

The West Lake Landfill is biologically and ecologically diverse. Rather than a single ecological system (e.g., a prairie), it is a mosaic of small habitats associated with (1) moist bottomland and farmland adjacent to the perimeter berm
(2) poor quality drier soils on the upper exterior and interior slopes of the berm

(3) an irregular waste ground surface associated with the inactive portion of the landfill (4) aquatic ecosystems present In 7ow spots on the waste ground surface

Generally, the natural systems which are present are limited by operations in the active portion of the landfill and form a corridor along the perimeter berm
from near well! site 75.*fF-i-gure 2.5), on the Old St. Charles Rock Road, clockwise

to the main entrance to the landfill near well site 68, along St. Charles Rock

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Road. The following observation and descriptions demonstrate the biological variety of these sites.

The flora of the perimeter berm extending from the southwest clockwise to the area of the main entrance to the landfill present a series of contrasts. Along the Old St. Charles Rock Road, the bottom and lower slope of the berm is heavily influenced by the nearby mature silver maple (Acer saccharinum). boxelder (Acer negundo), oak (Quercus), sycamore (Platanus). green ash (Fraximus pennsylvanica), and eastern cottonwood (Populus del toides) trees associated with the old channel of Creve Coeur Creek. At the corner, between wells 59 and 60 (Figure 2.5), large silver maple and boxelder trees form a dense stand in the moist soils at the base of the berm. The density of these trees declines on this slope extending toward the north (well 61) and the Butler-type Building corner. The extension of this slope toward the northwest is dominated by a dense willow-like thicket in which a few eastern cottonwoods and a hawthorn tree have established. From this northwest corner of the landfill to the eastern limit of the trees between the landfill and St. Charles Rock Road (well 65), the exterior slope of the berm is dominated by dense stands of small and large eastern cottonwoods. This latter occurrence reflects the influence of the well-established eastern cottonwoods and sycamores associated with the permanent pond just north of this site (Figure 2.9). The ground cover along these exterior slopes consists of grasses, forbs, plants common to disturbed areas, seedling cottonwoods, and shrubs. A well-manicured grass groundcover continues from the limit of the trees to the area around the main entrance of the landfill and well 68. This vegetation contributes to the partial stabilization of the steep exterior slopes.
The somewhat drier top and the short, interior slope of the berm, colonized by prairie grasses such as bluestem (Andropogon), blends into the irregular surface of the inactive portion of the landfill. Depressions in this surface allow water to collect and tall grasses, foxtail, and plants characteristic of disturbed areas [e.g., ragweed (Ambrosia), mullein (Verbascum). pokeweed (Phytolacca). cinquefoil (Potentilla). sunflower (Helianthus). and plantain (Plantago)] are replaced by characteristic wetland species [e.g., algae (Spirogyra). cattails (Typha), sedges (Carex), and smartweed (Polygonium)]. Young eastern cottonwoods are established at several of these wet sites. 2-12

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Generally, the surface vegetation of the inactive landfill gives way to barren waste ground around the Butler-type Building location and the barren terrain associated with recent landfill activities.

Animals were observed associated with these habitats. Cottontail rabbits (Sylvilagus) were encountered most frequently and their fecal pellets were observed on the landfill. Density of fecal material was particularly heavy in the thickets on the exterior slopes of the perimeter berm. In this regard, coyote (Cam's.latrans) feces containing rabbit fur were observed. Small mammals (rodents) were not seen but could certainly be present in these areas. Large ungulates also were not sighted, but tracks and feces of white-tailed deer indicate that they utilize the landfill.
The only birds observed were a crow (Coryus), several robins (Turdus), and whitecrowned sparrows (Zonotrichia leucophrys). This certainly does not reflect the extent to which birds utilize these habitats, for observations were made early in the spring. It is readily apparent that returning migratory passerines would utilize the surface vegetation and berm thickets for nesting, cover, and feed later in the season. It is also possible that waterfowl could utilize the permanent ponds on the landfill and adjacent to St. Charles Rock Road. Twelve scaup (Aythya) and mallards (Anas) were observed on the lagoon which serves as part of the landfill waste water treatment facility.

Small puddles contained characteristic aquatic invertebrates and at least two

species of amphibians. Casual examination of these shallow waters revealed three genera of snails (Physa. Lymnaea, Helisoma). an isopod (Asnellus). cyclopoid copepods, and cladocerans. Aquatic insect larvae were not observed; however, this does not rule out their presence. The sighting of a bullfrog tadpole (Rana catesbeiana) and audition of spring peepers (Hyla). indicates these ponds are utilized as breeding sites. No fish were observed in these puddles on the landfill surface; however, a dead gizzard shad (Dorsoma cepedianum) was seen in the pond adjacent to St. Charles Rock Road. The only reptiles seen were the water snake (Nerodia) and the garter snake (Thamnophis). Although the northwest inactive portion of the landfill is posted with "No Trespassing" signs, it was evident that humans do encroach on these habitats.
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Fishing tackle was found tangled In power lines and trees, and spent smallgauge shotgun shells were found on the landfill surface and berms.
2.11 Demographics

The West Lake Landfill is located in the northwestern portion of the city of Bridgeton, in St. Louis County, Missouri. Earth City Industrial Park is located on the floodplain 1.5 to 2 km ( 0 . 9 to 1.2 miles) northwest of the landfill. Population density on the floodplain is generally less than 10 persons per square kilometer (26 persons per square mile); and the daytime population (including factory workers) is much greater tfian the number of full-time residents. Major highways in the area include Interstate 70 (1-70) and Interstate 270 (1-270), which meet south of the landfill at Natural Bridge Junction (Figure 1 . 1 ) . The Earth City Expressway and St. Charles Rock Road lie, respectively, west and east of the landfill. The Norfolk and Western Railroad passes about 1 km ( 0 . 6 mile) from the northern portion of the landfill (Figure 1 . 1 ) . Lambert Field International Airport is located 6 km (3.7 miles) east of the West Lake Landfill. In addition to factories at Earth City, plants are operated by Ralston-Purina: and Hussman Refrigeration across St. Charles Rock Road. The employees of • these two plants probably comprise the largest group of individuals in close proximity to the contaminated areas for significant periods of time. The Ralston-Purina facilities are located 0.4 km (0.2 mile) northeast of the Butler-type Building location at the landfill. Considering that land in this area is relatively inexpensive and that much of it is zoned for manufacturing, industrial development on the floodplain will likely increase in the future.
Two small residential communities are present near the West Lake Landfill.

Spanish Lake Village consists of about 90 homes and is located 1.5 km ( 0 . 9 mile) south of the landfill, and a small trailer court lies across St. Charles Rock; Road, 1.5 km ( 0 . 9 mile) southeast of tl-- site (Figure 2.1). Subdivisions are presently being developed 2 to 3 km (1.2 to 1.9 miles) east and southeast of the landfill in! the hills above the floodplain. Ten or more houses lie east of the
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landfill scattered along Taussig Road. The city| of St. Charles is located north of the Missouri River at a distance greater than 3 km (1.9 miles) from the landfill, :

Areas south of the West Lake Landfill are zoned residential; areas on the other sides are zoned for manufacturing and business (Figure 2.2). Most of the landfill is zoned for light manufacturing (M-l). However, approximately 0.3 km2 (0.12:mi2) of the northern portion of the landfill is zoned for residential use; this includes the contaminated area around the Butler-type Building site. The field northwest of the landfill between Old St. Charles Rock Road and St. Charles Rock Road is under cultivation. • Trends indicate that the population of this area will increase, but the land will probably be used primarily for .industrial facilities.

3.1 Radiological Surveillance Approximately 43,000 mt (47,000 tons) of contaminated soil were reported to have i been disposed of in the landfill. A fly-over radiological survey performed for .the NRC in 1978 identified two areas of contamination at the West Lake Landfill. Subsequently, from August 1980 through the summer of 1981, the Radiation Management Corporation (RMC), under-contract to the NRC, performed an onsite evaluation of the West Lake Landfill (NRC, NUREG/CR-2722). The purpose of this survey was to clearly define the radiological conditions at the landfill. The results were to be utilized in performing an engineering evaluation to determine if remedial actions should and could be taken. The area to be: surveyed was divided into 10-m (33-ft) grid blocks and included the following measurements: (1) external gamma exposure rates 1m (3.3 ft) above the surfaces and betagamma count rates 1 cm (0.4 in.) above surfaces (2) radionuclide concentrations in surface soils
(3) radionuclide concentrations in subsurface deposits

I
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B _

• I
•

I
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(4)

gross activity and radionuclide concentrations in surface and subsurface water samples

(5) radon flux emanating from surfaces (6) airborne radioactivity

I

(7) gross activity in vegetation

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3.2 Survey Results External Gamma

Figure 3.1 snows the two areas of elevated external radiation levels as they existed in November I960, at the time of the preliminary RMC site survey. As can be seen, both areas contained locations where levels exceeded 100 uR/hr at 1 m (3.3 ft): In Area 2, gamma levels as high as 3000 to 4000 uR/hr were detected. The total areas exceeding 20 uR/hr were about 1.2 ha (3 acres) in Area 1 and 3.6 ha (9 acres) in Area 2. External gamma levels measured in May and July of 1981 decreased significantly, especially in Area 1, because approximately 1.2 n (4 ft) of sanitary fill was added to the entire area and an equal amount of construction fill was added to most of Area 2. As a result, only a few hundred square meters (a few thousand square feet) in Area 1 exceed 20 uR/hr. In Area 2, the total area exceeding 20 uR/hr decreased by about 10%, and the highest levels were about 1600 uR/hr, near the location of the Butler-type building.
Surface Soil Analyses

A total of 61 surface soil samples were gathered and analyzed on site for gamma activity. Samples were normally stored 10 to 14 days to allow ingrowth of radium daughters. Concentrations of U-238, Ra-226 (from Pb-214 and Bi-214), Ra-223, Pb-211, and Pb-212 were determined for each sample. Surface soil samples are located in Figures 3.2 and 3.3. In all soil samples, only uranium and/or thorium decay chain nucTides and K-40 were detected. Offsite background samples were on the order of 2 pCi/g Ra-226. Onsite samples ranged from about 1 to 21,000 pCi/g Ra-226, and front less than 10 to 2100 pCi/g U-238. In those cases where elevated levels of Ra-226 were detected, the concentrations of U-238 were generally anywhere from a factor of 2 to 10 lower. In cases of elevated sample activity, daughter products of both U-238 and U-235 were found.

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In general, surface activity was limited to Area 2, as indicated by surface beta-gamma measurements. Only two small regions! in Area 1 showed contamination; both were near the access road across from the site offices. In addition to onsite gamma analyses, 12 samples!were submitted to RMC's radiochemical laboratories for thorium and uranium radiochemical determinations. The i i results show all samples contain high levels of fh-230. The ratio of Th-230 to Ra-226 (Bi-214i) is about 20 to 1. Subsurface Soil Analysis

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Subsurface contamination was assessed by extensively "logging" holes drilled through the landfill. Several holes were drilled in areas known to contain contamination, then additional holes were drilled at intervals in all directions until no further contamination was encountered. A total of 43 holes were i drilled, 11 iniArea 1 and, in Area 2, 32 including i 2 nearby offsite wells for monitoring water. All holes were drilled with a'S-in. auger and lined with 4-in. PVC (polyvinyl chloride) casing. The location of these auger holes is shown in
Figures 3.4 and 3.5.
•

Each hole was scanned with an Nal(Tl) detector and rate meter system for an initial indication of the location of subsurface contamination. On the basis of the initial;scans, 19 holes were selected for detailed gamma logging using the intrinsic germanium (IG) detector and multiple channel analyzer. The results of, the Nal(Tl) counts and IG analyses show concentrations of Bi-214, as determined by the IG system, ranged from less than 1 to 19,000 pCi/g. For those holes where both Nal(Tl) counts and IG counts were made, a good correlation between gross Nal(Tl) counts and Ra-226 concentrations, as determined by in situ analysis of the daughter Bi-214 by the IG system, was found.

It was determined that the subsurface deposits extended beyond areas where surface radiation measurements exceeded 5 pCi/g. The approximate area of subsurface contamination compared to the area of elevated surface radiation levels shows a total difference in areas of 2 ha (5 acres).

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The variations of contamination with depth for Areas 1 and 2 are shown in Figure 3.6. As can be seen, the surface elevations vary by about 6 m (20 ft), and the highest elevations occur at locations of fresh fill. Contamination (>5 pCi/g Ra-226) in several areas is found to! extend from the surface to appreciable depths, about 6 m (20 ft) below the surface in two cases. In general, the subsurface contamination appears to be a continuous single layer, ranging from 0.6 to 4.6 m (2 to 15 ft) thick, located between elevations of 139 to 144 m (455 to 480 ft) and covering 6.5 ha (16 acres) total area. In Figures 3.7 and 3.8, representations of the subsurface deposits are provided on the basis of auger hole measurements. These representations are consistent with the operating history of the site, which suggests that the contaminated material was moved onto the site and spread as cover over fill material. Thus, one would expect a fairly continuous, thin layer of contamination, as indicated by survey results.
Nonradiological Analysis Six composite samples were submitted to RMC's (Environmental Chemistry Laboratory for priority pollutant analysis. Five samples were taken from auger holes (one from Area 1 and four from Area 2) and the sixth from the West Lake leachate treatment plant sludge. The results indicate a significant presence of organic solvents in Area 2 samples. The results of the leachate sludge analysis were not as high as any of the soil samples.

A chemical analysis of radioactive material from both areas was also performed by RMC's laboratory. Results show elevated levels of barium and lead in most cases. Background Radioactivity Measurement

Various offsite locations were selected for reference background neasurements. The results of these measurements were within the normal range.

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Airborne Radioactivity Analyses

Both gaseous and particulate airborne radioactivity were sampled and analyzed during this study. Since it was known that the buried material consisted partially or totally of uranium ore residues, the sampling program concentrated on neasuring radon and its daughters in the air. Two methods were used: the first was a scintillation flask method for radon gas and the second was analysis of filter paper activity for particulate daughters.
A series of grab samples using the accumulator method were taken between May and August of 1981. A total of 111 samples from! 32 locations was collected. 2 Measurable radon flux levels ranged from 0.2 pCi/m s in low background areas i ' 2 1 to 865 pCi/m s in areas of surface contamination . At three locations, repetitive measurements were made over a period of 2 months. These results are plotted in Figure 3.9. As can; be seen, significant fluctuations were observed at two locations. The fact that these fluctuations were real and not measurement artifacts was later confirmed by duplicate charcoal canister samples, as described below.
' •

A total of 35 charcoal canister samples was gathered at 19 locations over a 3-month period. The results show levels ranging from 0.3 pCi/m2s to 613 pCi/m2s. On 24 different occasions, the charcoal canisters and accumulator were placed in essentially the same locations, at the same time, for duplicate sampling. The results of this side-by-side study show generally good correlation between the two methods.
A set of 10-minute high-volume particulate air samples was taken to determine both short-lived radon daughter concentrations and long-lived gross alpha activity. The highest levels were detected in November 1980, near and inside the Butler-type building which has since been removed. These two samples approximately equal NRC's 10 CFR Part 20, Appendix B, alternate concentration limit of one-thirtieth WL for unrestricted areas.

In addition to the routine 10-minute samples, five 20-minute high-volume air samples were taken and counted immediately on the IG gamma spectroscopy system
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to detect the presence of Rn-219 daughters. All samples were taken near suri I face contamination. In addition to Rn-222 daughter gamma activities, Rn-219 daughters were detected by measuring the low-abundance gamma rays of Pb-211. Concentrations of Rn-219 daughters ranged from!6 x 10-11 to 9 x 10-10 uCi/cc. Vegetation Analysis

Vegetation samples included weed samples from onsite locations and farm crop samples (winder wheat) near the northwest boundary of the landfill. This location was chosen because runoff from the fill onto the farm field was possible. No elevated activities were found in these samples. **
Water Analyses A total of 37 water samples was taken: 4 in the fall of 1980, and the remainder in the spring and summer of 1981. One sample was equal to the U.S. Environmental Protection Agency (ERA) gross alpha activity standard for drinking water of 15 pCi/liter and that was a sample of standing!water near the Butler-type building. Several samples, including all the leachate treatment plant samples, exceeded the EPA drinking water screening level for gross beta which would require isotopic analyses. Subsequent isotopic analyses indicated that the beta activity could be attributed to K-40. None of the offsite samples *, exceeded either EPA standard or screening level.

In 1981, MONR collected 41 water samples which RMC analyzed for radioactivity (Table 3.1). Of these samples, 5 were background, 10 were onsite surface water, 10 were shallow groundwater standing in boreholes, and 16 were landfill leachate. From these data, background activity is estimated as 1.2 pCi/liter gross alpha and 27 pCi/liter gross beta. Results in Table 3.1 show the gross alpha in two water samples exceeded or equaled 15 pCi/1; the gross beta in ten water samples exceeded 50 pCi/1. Most of the gross beta activity comes from naturally occurring K-40 as determined from subsequent isotopic analysis. In addition, groundwater samples in perimeter monitoring wells at the West Lake Landfill were taken by UMC personnel and ORAU 1n 1983, 1984, and 1986. The well locations are shown in Figure 2.5 and! the results are presented in 3-6

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Tables 3.2 and 3.3. Results in Table 3.2 show the gross alpha in two water samples slightly exceeded 15 pCi/1; the gross beta were all below 50 pCi/1 in all water samples. Table 3.3 shows analyses were below 15 pCi/1 for gross alpha and 50 pCi/1 for gross beta for all the wells.

3.3 Estimation of Radioactivity Inventory
In examining the RMC report for bore hole samples (Table 3.3), it is noted that ' i the naturally ioccurring U-238 to Th-230 to Ra-226 equilibrium has been disturbed. The RMC report (NRC, NUREG/CR-2722) indicates that the ratio of Ra-226 to U-238 is on the order of 2:1 to 10:1. Thi:s observation 1s consistent with the history of the radionuclide deposits in the West Lake Landfill, i.e., that they came from the processing of uranium ores to extract the uranium content and that the radioactive material at West Lake came from the former Cotter Corporation facility on Latty Avenue (presently occupied by iFutura Coatings Company) in Hazelwood, Missouri. This location contains contamination from ore processing residues from which uranium had been previously separated, leaving the daughters behind at relatively higher concentrations. Additionally, it is noted in the RMC report that the ratio of Th-230 to Ra-226 is on the order of 5:1 to 50:1. This indicates that radium has also been removed. Other data are available in the Latty Avenue site study (Cole, 1981). Table 3.4 presents the radionuclide concentrations in Latty Avenue composite samples1. Using the RMC data and averaging the auger hole measurements over the two volumes of radioactive material found in Areas 1 and 2, a mean concentration of 90 pCi/g was calculated for Ra-226. Also, the ratios of Th-230 to Ra-226 were established since the level of Th-230 will determine the increase of Ra-226 with time. Although the ratio of Th-230 to Ra-226 ranged from 5:1 to 150:1, most of the data were in the 30:1 to 50:1 range. To ensure conservatism in estimating the long-term effects of Ra-226, a ratio of 100:1 was used for all further

calculations.
Using the Th-230: Ra-226 ratio of 100:1, the Th-230 activity is 9000 pCi per gram. If the U-238 concentration (as well as U-234 which would be similarly separated from the ore) is a factor of 5 less than Ra-226, this implies about 18 pCi U-238 per gram. The total mass of radioactive material (having Ra-226

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concentrations of 5 pCi/g or more) in the landfill was estimated by visually integrating the volume of radioactive material jfrom graphs and multiplying by an average soil density, resulting in 1.5 x 101!1 grams (150,000 metric tons) of contaminated soil. These numbers indicate that there are about 14 Ci of Ra-226 contained with its decay products in the radioactive material in the landfill. The material i also contains about 3 Ci each of U-238 and U-234, and about 1400 Ci i of Th-230. These estimates indicate the order lof magnitude of the quantities to be dealt with, although the estimate for Th-230 is regarded as conservatively large.

*Samples taken November 15, 1983. **Samples taken March 21, 1984, by UMC personnel, analyzed by Environmental Health Lab of St. Louis County Health Department, Clayton, Missouri. ***Well #50 used as background.

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Table 3.3

Radionuclide concentrations in well water samples: May 7-8, 1986
Concentrations (pCi/1)

"Based on Ra>228 and assumption of secular equilibrium of thorium decay series. **Errors are 2o based only on counting statistics.

Source:
ro en

Table 2 (Cole, 1981).

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4 APPLICABILITY OF THE BRANCH TECHNICAL POSITION

The NRC has established a Branch Technical Position (BTP) which identifies five acceptable options for disposal or onsite storage of wastes containing low levels of,uranium and thorium (46 FR 52061, October 23, 1 9 8 1 ) . Options 1-4 provide methods under 10 CFR 20.302, for onsite disposal of slightly containinated materials, e.g., soil, if the concentrations of radioactivity are small enough and other circumstances are satisfactory. The fifth option consists of onsite storage pending availability of an appropriate disposal method. Table 4.1 shows the Vadionuclide concentrations specified for the disposal options.
The material present in the West Lake Landfill is a form of natural uranium with daughters, although the daughters are not now in equilibrium. As mentioned above, the average concentration of Ra-226 in the West Lake Landfill wastes is about 90 pCi per gram, which (considered by itself) falls into Option 4 of the BTP since Option 4 criteria are controlled by the Ra-226 content in the wastes (i.e., 200 pCi of U-238 plus U-234 per gram would be accompanied by 100 pCi of Ra-226 per gram). However, because of the large ratio of Th-230 radioactivity to that of Ra-226, the radioactive decay of the Th-230 will increase the concentration of its decay product Ra-226 until these two radionuclides are again in equilibrium. Assuming the ratio of activities of 100:1 used above, the Ra-226 activity will increase by a factor of five over the next 100 years, by a factor of nine 200 years from now, and by a factor of thirty-five 1000 years from now. All radionuclides in the decay chain after Ra-226 (and thus the Rn-222 gas flux) will also be increased by similar multiples. Therefore, the long-term Ra-226 concentration will Jc. exceed the Option 4 criteria.

Concentration based on limiting equivalent exposure to 0.02 WL or less Concentrations based on limiting individual intruder doses to 500 mrem per year 'and, in cases of natural uranium, limiting exposure to Rn-222 and its decay product airborne alpha emitters to 0.02 WL or less. ,.•

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5 REMEDIAL ACTION ALTERNATIVE CONSIDERATIONS

The radioactive Material as it presently exists does not pose an imediate *. health hazard for Individuals living or working in the area of the landfill. However, there 1s a long-term potential for the radioactive material to pose a health problem. Therefore, this section discusses six (A-F) possible courses of action, of which all but A and D are considered temporary. Option A. in which no remedial action 1s proposed, 1s unacceptable because the concentrations of radionuclides in the landfill will become too high^ Option A Is described for comparison purposes only. Costs are based on the Oodge Guide to Public Works and Heavy Construction, 1984.^1
5.1 Option A: No Remedial Action

Under Option A, no remedial work would be done on the West Lake site. The landfill and the radioactive soil would be left in their present condition. The contaminated areas would be available for demolition fill emplacement and final closure. It is not certain how much additional fill would be emplaced. Filling would be followed by normal landfill closure operations. Normal closure procedures consist of applying at least 0.61 m (2 ft) of compacted final cover. A 0.3-m (1 ft) layer of topsoil would be placed over the cover and upgraded to support vegetation. Establishment of a vegetative cover would require seeding, liming, and fertilization. Surface seeps of leachate would be eliminated. Maintenance of the monitoring wells would be required to allow continued sampling by MDNR, should MDNR require such action. The public would be discouraged from entering the site. After closure, a detailed description of the site would be filed with the County Recorder of Deeds. This description would include: a legal description of the site, types and location of wastes present, depth of fill, and description of any environmental control or monitoring systems requiring future maintenance (MDNR, January 1963). MDNR regulations also specifically prohibit excavation or disruption of the closed landfill without written approval of MDNR; no time frame is stated with this regulation; (MDNR, 1975).
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1 1 1
1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1

There would be no further cost under this option since no remedial actions would be taken; i.e., costs are normal landfill costs.
5.2 Option B: Stabilization on Site With Restricted Land Use

" Two areas in1 the landfill contain radioactive material. Therefore, the work required for this option is described separately for each area. Nevertheless, restrictions would be imposed on the use of land within each area. This would discourage future activities on these areas which might expose individuals to radioactivity. No additional landfill would be permitted to be deposited on either area. •'• Area 1 It is believed that a total of 2 to 3 m (7 to 10 ft) of soil has been added to most of Area 1 since the 1981 land survey by RMC. This cover has altered the radiation environment of the site. Measurements by Oak Ridge Associated Universities (ORAU) personnel in March 1984 (Berger) showed that only a very small area exceeded the exposure rate of 20 uR/hr at 1 m. By extending the cover_20 m (66 ftl outward in all directions from the area showing an/unacceptable surface exposure rate, the shallow wastes likely to give high rates of radon emanation will also be covered. The amount of radioactive debris in Area 1 is relatively minor compared with that present in Area 2. Therefore, a _£p-n rnvor nf 1 ^ m (5 ft^ TS rnnciriereri adequate tn reduce surface exposure rates and radon emanation. After the soil cover is in place, a layer of topsoil^0.3 m (1 ft) thick would be emplaced, seeded, and mulched.
1

Area 2

Vegetation over Area 2 as well as on the slope of the berm would be cleared and placed in the demolition portion of the landfill or disposed of as is convenient. Brush should not be left in place and covered since this may reduce the integrity of the soil cap. Grass should be mowed, and may be left In place.

The berm on the northwest portion of the landfill which contains an estimated 7,500 m3 (9,800 yd3) of contaminated soil would be excavated and redeposited in
5-2

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layers in a secure portion of the landfill. The actual amount can be determined by survey during implementation of the work.
All equipment and materials now stored over Area 2 would be removed to other portions of the site or disposed of as is convenient to the owners. Gravel piles found oh Area 2 should be removed to other portions of the site after having been surveyed to ensure that contaminants have not been mixed with the gravel. However, the lower 10 to 15 cm (4 to 6 in.) of rock should be left in place and covered with the soil cap, since this gravel may have become mixed with contaminated soil.

I I I I I I I I I I I I I I I I I

Such stabilization would place the contaminated soil well below the surface and would prevent radioactive materials from eroding as can now occur along sections of the berm. 'Stabilization would require emplacement of a soil cover of 48,000 m3 (63,000 yd3) to give a final slope of 3:1 with 1.5 m (5 ft) of soil at the top of the berm. At least 1.5 m (5 ft) of soil cover would be used, as this much soil will be required to reduce radon gas exhalation. The final slope of 3:1 on the berm would be shallow enough to prevent failure and, after the cover is emplaced, it should be further covered with at least 0.3 m (1 ft) of topsoil and seeded with native grasses to prevent erosion. The slope would be directed radially outward from the center of the cap. An interceptor ditch would be provided around the cap to channel runoff and prevent gullies from being cut into the stabilized cover. The cover soil presently used in the landfill ing operations may be used to stabilize the berm. This soil is a clay silt (loess) excavated near the West Lake Landfill site.
The portion of Area 2 to be covered by the soil cap includes that portion of the landfill identified in the RMC survey as having surface exposure rates greater than 20 pR/hr at 1 m (3.3 ft) above ground level, along with those areas in which auger holes revealed radium-bearing soil within 1 m of the surface. The shallow contaminants may be sufficiently shielded to produce low surface exposure rates; however, these shallow deposits will still produce radon emanations greater than the desired level of 20 pCi/m2s. Therefore, the soil cover must be extended over these areas of shallow contamination.

5-3

I I I I I I I I I I I I I I I I I I I

The cover soil used should be capable of compaction to a permeability of less than 10-7 cra/s in order to keep radon release and soil leaching as low as possible. This value is based on common practices used for sealing of hazardous waste landfills. Because accurately measuring permeability of this magnitude is difficult, the value of 10-7 cra/s should be used only as a target criterion which should, if possible, be bettered. If laboratory testing of the cover soil presently used at the West Lake Landfill indicates that this permeability can be achieved, this soil would be acceptable for use as the soil cap. Otherwise, clay soil would have to be imported from off the site to be used in constructing the soil cap. i The overall estimated cost for the required work under Option B is approximately $360,000 (Table 5.1) and would require about 2 months to complete. Costs of this option may be higher if the total quantity of contaminated material to be moved is higher than the estimated quantity. 5.3 Option C: Extending the Landfill Off Site Soil eroding on the northwest berm of Area 2 is carrying contaminated soil off the landfill property onto an adjacent cultivated field. A contributing factor to the erosion is the steepness of the berm. It would, therefore, toe desirable to lessen the slope's steepness by extending the berm onto the adjacent field. This option would require the acquisition of approximately 2 ha (5 acres) of land not owned by the landfill company. In this option, Area 1 would be treated the same as in Option B. The contaminated portion of the northwestern berm of Area 2 would not be disturbed. Instead the existing; berm would be extended 13 to 16 m (42 to 52 ft) onto the adjacent field. This would require an additional solid volume of approximately 20,200 m3 (26,400 yd3) to give a final slope of 3:1 with 1.5 m (5 ft) of soil on top of the berm. As in Option B, this cover should receive an additional 0.3 m (1 ft) of topsoil and be seeded with native grasses to prevent erosion. This option will require the relocation of three transmission poles. All other necessary work for Option C is as described for Option B.

.5-4

I I I I I I I I I I I I I I I I I I I

The overall estimated cost for required work under Option C is approximately $470,000 (Table 5.2) and would require about 2 months to complete. The extent of work required under this option is well defined.

5.4 Option D: Removing Radioactive Soil and Relocating It

This option would involve excavating and removing all contaminated soil and debris from the West Lake Landfill and relocating it to an authorized disposal facility.

Vegetation over Areas 1 and 2 would 'be cleared and placed in the demolition portion of the West Lake Landfill.
All equipment stored on the two contaminated areas would be removed to another portion of the site. Gravel piles in Area 2 should be removed. The lower 10 to 15 cm (4 to 6 in.) of rock should be left in place to be disposed of with other contaminated materials, since this gravel may have become mixed with contaminated soil at the surface.
The areas known to contain radioactive contamination at levels above the action criteria (20 pR/hr at 1 m) would be excavated initially. Next, the excavated area would be surveyed to determine the extent of contamination remaining. Excavation would continue until unacceptable levels of contamination have been removed. Immediately after excavation, the soil would be placed in 208-liter (55 gal) approved drums (or other approved containers) for transport. Containment in the drums will prevent the spread of dust and loose soil during transport. Some of the nonradiological hazardous material known to be present in the landfill could present a serious danger to workers should they excavate into this material. Proper precautions should, therefore, be taken as the work is being performed. Estimated costs under Option 0 would be $2,500,000 (Table 5.3). Transporting the contaminated soil to another site and emplacing the material there would significantly,add to the cost. This option could be completed in about

5-5

I I
1

3 months, providing that a suitable disposal facility were available to receive the contaminated waste. 5.5 Option E: Excavation and Temporary Onsite Storage in a Trench

1

I

I I I I I I I I I I I I I I

Under this option, as much radioactive soil would be excavated as in Option D and would be placed in a specially prepared trench on the West Lake site but would not be placed in drums. This trench would become a temporary repository for the radioactive soil. The trench would be surrounded by an impervious clay liner to minimize leachate production and transport into the groundwater system. The cap should give acceptable rates of surface exposure and acceptable rates of radon gas release.
As under Option 0,, surface vegetation, machinery, and piles of crushed rock would be removed from the surface of areas to be excavated. Design of the trench is based upon the "secure landfill concept" (Shuster and Wagner, 1980) with three primary functions: eliminate direct gamma-ray exposure at the ground surface, reduce radon emanation, and prevent leaching of radionuclides to the groundwater system.
The excavated area would be cut to a maximum elevation of 140 m (460 ft) msl over the area to be covered by the trench. The base of the trench would cover an area 120 x 120 m (394 x 394 ft) and would have a negligible slope. Low spots would be filled with borrow soil* compacted to at least 90% of its standard Proctor density (SPO). Once the base for the trench has been leveled to a final elevation of about 140 m (460 ft) msl, a blanket of borrow soil at least 1.5 m (5 ft) thick compacted to at least 90% SPD would be emplaced. Specification of compaction of this underlayer is based on the requirement of avoiding subsidence which could cause the clay liner to crack and fail. A clay liner would be placed above the underlayer. The liner would be 0.5 m (1.6 ft) thick and would nave a permeability less than 10-8 cm/s (4 x 10-9 in./s). An impermeable plastic liner could also be used.

*Borrow soil refers to a clayey-silt loess (Soil Conservation Service type CL) excavated; southeast of the site for use as daily cover in the landfill ing operation.
5-6

I I I I I I I I I I I I I I I I I I I

Sides of the trench would be built at a 3:1 slope up to the level of the surrounding undisturbed landfill surface, about 143 m ( 4 7 0 ft) msl. The walls would consist of an underlayer and liner as described for the base. A layer of crusher-run limestone 0.5 m ( 1 . 6 ft) thick would be placed on top of the liner to allow leachate buildup in the trench to be monitored and to facilitate pumping should leachate buildup become a problem.

After the base and walls of the trench have been built, the previously excavated debris would be placed in the trench. Then the remaining radioactive debris would be excavated and placed in the trench. As excavation proceeds, it will become apparent how much volume the trench must have to contain all the contaminated soil. At this point, the walls of the trench would be raised to an appropriate level. Excavation and filling can then proceed until the work is complete. The final thickness of debris is expected to be from 4 to 6 m (13 to 20 ft). A cover, as described below, would be placed over the debris. A 1 m (3 ft) layer of borrow soil compacted to 90% SPO will be placed over the debris. A clay liner 0.5 m ( 1 . 6 ft) thick of permeability less than 10-8 cm/s (4 x 10-9 in./s) would be placed over the borrow soil blanket. A 0.5-m (l.-6-ft) layer of crusher-run limestone would be placed over the clay layer to prevent infiltration water from building up over the liner. A cover soil layer of average thickness about 2 m (7 ft) would be placed over the rock layer. The cover soil would be compacted and built with a surface slope of from 2% to , 4% to minimize erosion. Three-tenths of a meter (1 ft) of top soil would be placed over the cover layer and would be seeded and mulched to establish a vegetative cover.
Once the trench has been prepared to accept the soil, workers may begin to excavate contaminated soil. As under Option C, an initial excavation would remove the area of known contamination, and a cleanup phase would remove all soil containing radionuclide concentrations above an action level of 15 pCi/g Ra-226. As soon as the soil has been excavated, it would be hauled to the trench and emplaced. The contaminated soil should be sufficiently compacted to

5-7

I I I I I I I I I I I I I I I I I I I

prevent settling, to maintain the integrity of the soil cap. As fill is being emplaced, the pipe for a monitoring well would be extended upward from the base of the gravel underdrain. This well should be designed in a manner that would allow future installation of a pump for drawing off leachate should this become necessary.
i

Costs for Option E would be approximately $2,150,000 (Table 5 . 4 ) . The estimated costs vary somewhat, since the exact limits of excavation cannot be defined until work begins. This work would require approximately 4 aonths to complete. 5.6 Option F: Construction of a Slurry Wall to Prevent Offsite Leachate Migration

Under Option F, radioactive soil would be left in place at the West Lake site. The wastes would be stabilized by means of a soil cover (as under Option B) and a downgradeent slurry wall would be built around the contaminated soil. The slurry wall would be intended to keep leachate from migrating off site. This remedial action would be somewhat more effective than Option B in reducing the potential for groundwater contamination. However, costs incurred would be substantially higher than those for Option B or C. Benefits would be'nearly identical to those derived by the soil cover and berm stabilization alone; the sole advantage of Option F over Option B or C would be greater protection to » groundwater in the Missouri River alluvium.
Vegetation, machinery, and piles of crushed rock would have to be removed as described for Option B. A slurry wall would be constructed by excavating a trench [approximately 1 m (3.3 ft) wide] to the depth of bedrock. This trench would be bored out in the presence of a mud weighted with bentonite (clay) to keep the walls from collapsing and to keep groundwater from intruding into the trench. The trench would be excavated in sections 6 to 8 m (20 to 26 ft) long. Once a section of trench has been excavated, concrete would be poured by tremie into the trench to displace the slurry. The final slurry walls would each consist of a concrete slab about 1m (3.3 ft) thick extending to bedrock and partially-encircling the bodies of radioactive soil in both Areas 1 and 2. A total of approximately 1300 linear meters (4,300 ft) of wall would be constructed to depths varying from 5 to 15 m (16 to 50 ft).

5-8

I I I I I I I I I I I I I I I I I I I

After each of the slurry walls had been emplaced, fill would be added along the

face of the berm to stabilize the slope. Finally, a soil cover would be placed over the contaminated areas. The berm would be stabilized and the soil cover would be placed as outlined for Option B. Costs of work required for Option F would be approximately 45,600,000 (Table 5.5). The exact amount of slurry wall cannot be determined until work Is begun; therefore, this cost will be highly variable. Since the walls should extend to bedrock, the depth of soil and landfill debris will govern the depth of the required wall. Slight errors in estimating the depth of alluvium could result in large errors in the cost estimate. It is estimated that it would take 6 to 8 months to complete this option.

*Dodge Guide to Public Works and Heavy Construction, 1984. **Ford, Bacon and Davis Utah, Inc., "Engineering Evaluation of the Latty Avenue Site, Hazelwood, Missouri," NRC Contract No. NRC-02-77-197, 1978. (This Butler-type building has already been removed.) ***No costs have been included here for moving the waste, for emplacing it and for disposal facility users fees. tBased upon best estimate. ttEstimated quantity of soil having Ra-226 concentrations of 15 pCi/g or more.

This work was performed by EG&G for the United States Nuclear Regulatory Commission through an EAO transfer of funds to Contract No. DE-ACO8-76NVO1183 with the United States Department of Enersy.

I I

ABSTRACT An aerial radiological survey to measure terrestrial gamma radiation was carried out over the Mallinckrodt Nuclear Maryland Heights Facility during October 1977. At the same time the following properties were also surveyed: a parcel near 9200 West Latty Avenue, which included a portion of St. Louis International Airport; and land used by West Lake Landfill, Inc.. which is 8 km northwest of the airport. Gamma ray data were collected by flying parallel lines 60 m apart. The total area surveyed over the three sites was 7.4 km2. Processed data indicated that detected radioisotopes and their associated gamma ray exposure rates were consistent with those expected from normal background emitters, except at certain locations described in this report.
Average exposure rates 1 m above the ground, as calculated from aerial data, are presented in the form of an isopleth map. No ground sample data were taken at the time of the aerial survey.

residues and processed wastes were stored on the airport property. In early 19GG these ore residues and uranium-

maintains an aerial surveillance operation called
the Aerial Measuring System (AMS).' AMS is operated for DOE by EG&G. This continuing nationwide program, started in 1958. involves surveys to monitor radiation levels in and around facilities producing, utilizing, or storing radioactive materials. The purpose of the survey

bearing processed wastes were moved from the
airport property by the Continental Mining and Milling Company of Chicago. Illinois to the Latty

is to document, at a given point in time, the
location of all areas containing gamma emitting radioactivity (visible at the surface), and to aid

residues; much of the material was then dried and
shipped to the Cotter Corporation facilities in Canon City, Colorado. The source material

local personnel in evaluating the magnitude and spatial extent of any radioactive contaminants
released into the environment. At the request of DOE, or other federal and/or state agencies (such as the United States Nuclear Regulatory

remaining at the Latty Avenue site was sold to the
Cotter Corporation in December. 1969. Records indicate that residues remaining on the site at that time included 74,000 tons of Belgian Congo pitchblende raffinate containing about 113 tons of uranium; 32,500 tons of Colorado raffinate containing about 48 tons of uranium: and 8.700 tons of leached barium sulfate containina about 7 tons of uranium. During the period August through November. 1970 Cotter Corporation dried some of the remaining residues and shipped them to their mill in Canon City, Colorado. By December, 1970 an estimated 10.000 tons of Colorado raffinate and 8.700 tons

Commission), AMS is deployed for various aerial
survey operations.
AMS was utilized during the period 22-28 October 1977 to radiometrically survey an area 1.6 km2 centered on the Mallinckrodt Nuclear Maryland Heights Facility. Also surveyed was an area 3.2 km2 surrounding 9200 West Latty Avenue, which included a portion of the St. Louis International Airport A third site surveyed was a 2.6 km2 area centered on property operated by West Lake Landfill. Inc.. 8 km northwest of the airport.

of leached barium sulfate remained at the Latly
Avenue site. In April, 1974 a NRC inspector was informed that the remaining Colorado raffinate had been shipped in mid-1973 to Canon City without oryir.g ana (hat the leached barium sulfate'had been transported to a landfill area in St. Louis' County. A reported 12 to 18 inches of topsoil had been stripped from the Latty Avenue site: this supposedly had been removed with the leached barium sulfate. However, analyses of soil samples taken during a NRC investigation of the Latty Avenue site in 1976 indicated the presence of uranium- and thorium-bearing residues. The West Lake Landfill property is located off St. Charles Rock Road near Taussig Road, approximately 8 km northwest of the airport. 3.0 SURVEY METHOD AND AIRBORNE EQUIPMENT

The St. Louis International Airport was the survey

base of operation.
2.0 SURVEY AREA HISTORY AND LOCATION

The Mallinckrodt Nuclear Maryland Heights Facility is located at 2703 Wagoner Place, St. Louis, M i s s o u r i . This p l a n t r e c e i v e s radioisotopes from various vendors and converts

them to radio pharmaceutical materials. Radioisotopes which they handle include 13II, w'Tc.
•"Mo, «Se. and "Fe. Mallinckrodt Nuclear is a Division of Mallinckrodt, Inc. (formerly, Mallinckrodt Chemical Works). Mallinckrodt. Inc. acquired the Maryland Heights facility from •Nuclear Consultants. Inc. in 1965. It is reported in an ORNL report and a NRC report' that during the period 1942 through the late 1950's Mallinckrodt Chemical Works of St. Louis processed uranium ore. Some of the ore
'Formerly Aerial Measuring Systom (ARMS).
2

10
along the programmed flight lines on the photograph. The survey pattern consisted of parallel lines at 60m intervals. Flight altitude was 60 m. A Hughes H-500 helicopter was utilized for the survey (Figure 4). The H-500 carried a crew of two: pilot and navigator. The helicopter employed a lightweight version of the Radiation and Environmental Data Acquisition and Recorder system (REDAR). Two pods were mounted on the sides of the helicopter: each pod contained ten 12.7 cm diameter by 5.1 cm height Nal(TI) detectors. Gamma ray signals from the 20 detectors were summed and routed through an anaiog-to-digital converter and a piilso-height analyzer. Gamma spectra were accumulated in 3-second intervals and recorded on 1/2 inch magnetic tape.

mounted in the helicopter interrogated two remote transceivers mounted on towers outsid. the survey area. By measuring the round trip propagation time between the master and remoto stations, the master computed the distance to each. These distances were recorded on magnetic tape each second; in subsequent computer processing these were converted to position coordinates.
The radio altimeter similarly measured the time lag for the return of a pulsed signal and converted this to aircraft altitude. For altitudes up to 150 m. the accuracy was ± 6.6 m or ± 2%, whichever is greater. These data were also recorded on magnetic tape so that any variations in gamma signal strength caused by altitude fluctuation could be accurately compensated.

I I I I I I I I I I I I I I

This helicopter position was established with two systems: a Trisponder/202A Microwave Hanging System (MRS), and an AL-101 radio altimeter. The trisponder master station

The detectors and electronic systems which accumulate and record the data are described only briefly here. They are described in considerable detail in a previous report.1

Flflurtt

HUGHES H~SOO HELICOPTER CONTAINING THE

I
4.0 DATA PROCESSING

11
Data processing was done with the Radiation and
Environmental Data Analyzer and Computer system (REDAC). This is a computer analysis

and cosmic rays. Flights over the Missouri River were used for this purpose.
The corrected gross count rates were converted to exposure rates at 1 m altitude, with the factor ^1024 counts per second (cps) per ^/R/h obtained from calibration data over a Nevada test range.

tape drives, a Data General NOVA 840 computer, two Calcomp plotters, and a Tektronics CRT display screen. The computer has a 32 k-word core memory and an additional 1.2 x lO^-word disc memory. An extensive collection of software routines is available for data processing. The gross count data were corrected for system dead time and altitude deviation. Corrections to the gross count rates were also made for
contributions from radon, aircraft background,

5.0 DISCUSSION AND RESULTS Analysis of the radiological data taken over the area surrounding each of the sites discussed in this report indicates that the terrestrial /adioisotopes and associated gamma ray exposure rates were consistent with the natural
background normally found within areas having a

similar

geological basis. These background

exposure rates were in the 8-11 pR/h range,
including 3.7 //R/h due to cosmic rays.

f

i

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M
.S

^Tu

1^"

3A

Figure 5. MOBILE COMPUTER PROCESSING LABORATORY

12

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'Numbed are idjurea to • M OeteCIor

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Levels <co>t ' R

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———i———i———i
* IW

nOMiing ••io> 0^« !o P.IW p.> -O

Ground level iti.eiil.ng t^r'Ounct me
^__^_^_^_^_^_____<^

COUNTS PER CHANNEL 106 COUNTS FULL SCALE
5
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Is 8 *°§?is:^'i
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I I I I I I I I I I I I I I I I I
200 M) 400 HO MO METCftl
GROSS COUNT CONVERSION SCALE GAMMA -

EXPOSURE RATE

1m LEVEL

d*ucubto fwia-oi.
m tliitudi «no

lo m» 1 m

.

IndudM IT^Vhr cnmie tuition.

Figure 8. EXPOSURE M TE ISOPLE THS: LATTYA VENUE

I

5.2 Latty Avenue and Airport
t ujure 8 presents the exposure rate isopleths superimposed on an aerial photograph of the site. Figure 9 is a background-subtracted energy spectrum of the radiation characteristics of both areas of increased activity. Radiation from 2MBi accounts for all the major photopeaks observed. This isopleth map (Figure 8) is based on gross counts (integral counts in the energy region

between .05 MeV and 3 MeV). The factor used to convert these counts to the exposure rate at the 1 m level was determined from measurements at a calibration site containing a typical mix of naturally occurring radionuclidcs. Since the
spectrum shown in Figure 9 is different from a typical natural spectrum, the conversion factor may be in error. The isopleths, which represent ground level exposure rates for distributed sources, are consistent with sources whose

- A standard was not run and a measurable (near MDL) peak was not found at the expected retention time. •I - Tentative Identification has been ™ nade through a library search. An authentic standard has ni^been run. • The esp. conic, is baa£d/on jresponse

EXHIBIT 14-1 (Interim Report on the Proposed Ground Hater Sampling Program for the Primary Phase of the Hydrogeologic Investigation, West Lake Landfill, St. Louis County, Missouri, October 1985 prepared by Burns and McDonnell, Kansas City, Missouri) will be produced at such time as it is located by Respondent.

I I I I I I I I I I I I
I

'

I I I
I

•

EXHIBIT 14-J (Hydrogeologic Investigation - West Lake Landfill Preliminary Phase Report, dated January 1985 prepared by Burns and McDonnell, Kansas City, Missouri) will be produced at such time as it is located by Respondent.

I I I I I I I I I

i i i i -

rn oon

I I I I I I I I I I I I I I I I I I I

DUPLICATE
ST. LOUIS COUNTY DEPARTMENT OF COMMUNITY HEALTH & MEDICAL CARE DIVISION OF ENVIRONMENTAL HEALTH CARE SERVICES AIR POLLUTION CONTROL BRANCH

June 1, 1976
Date O P E R A T I N G P E R M I T

»»276
Number

This permit to operate the equipment/process(es) described below is granted to:

____________West Lake Quarry
Name

____________13570 St. Charles Rock Road Location of Equipment
Such operation to be pursuant to the conditions set out in Operating Permit Application No. :
Equipment/Process(es)

#1 Asphalt Batching Plant
Cyclone Collector

Model: 270 & 370

99.8* Efficiency
Stack/Vent Identification

Director Air FolluMon Control Branch

(This Pemit to be visibly affixed or placed in . accordance with Section 612.120 St. Louis County Air Pollution Control Code.) Ten Dollar ($10.00) fee paid.

I I I I I I I I I I I I I I I I I

ST. LOUIS COUNTY DEPARTMENT OF COMMUNITY HEALTH & MEDICAL CARE DIVISION OF ENVIRONMENTAL HEALTH CARE SERVICES AIR POLLUTION CONTROL BRANCH
August 7. 1979

04559
Number
P E R M I T

Date
O P E R A T I N G

This permit to operate the equipment/process(es) described below is granted to:
__________Westlake Quarry & Material___________

Name
__________St. Charles Rock Road & Tanggig Rr»ad

Location of Equipment Such operation to be pursuant to the conditions set out in Operating Permit Application No.:______2691 Equipment/Process(es)______________________
___________Dust Suppression System___________ ___________Make; Johnson-March_____________ ___________600 tons/hour___________________

Stack/Vent Identification
N/A

istajgrt Director Air Pollution Control Branch

(This Permit to be visibly affixed or placed in accordance with Section 61?. 120 St. Louir, County Air Pollution Control Code.) Ten Dollar (510.00) fee paid,

Blaine J. oades,' Program Manager Air Poll (This permit to be visibly affixe or placed in accordance with Section 612.120 St. Louis County Air Pollution Control Code.) Fee paid $_____

I

0010

_

STATE OF MISSOURI

• '
•

DEPARTMENT OF NATURAL RESOURCES
MISSOURI CLEAN WATER COMMISSION

I I

AUTHORIZATION TO DISCHARGE
• •
I

UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the Federal Water Pollution Control Act, Public Law 92-500, 92nd Congress, (hereinafter, the Act) as amended, and the Missouri Clean Water Law, (Chapter 644 R.S. Mo. Cum. Supp. 19R6, hereinafter, the Law).

/ (NW 1/4, SW 1/4, SE 1/4, Sec. 31 projected), T46N, R5E, St. Louis County Receivin<> Stream & Basin: Unnamed tributary to Missouri River (10300200-04-00) (Missouri River and Eastern Tributaries Basin) is authorized to discharge from the facility described herein, in accordance with the effluent limitations and monitoring requirements as set forth herein:

This permit only authorizes wastewater discharges under the NatiorpPolmfcHit Discharge Elimination System: it does not apply to other regulated areas. This permit may be appealed! in accordance with Section 644.051.6 of the Law. ' '

The permittee is authorized to discharge from outfall(s) with serial number(s) as specified in the application for this permit. The final effluent limitations shall become effective upon issuance and remain in effect until expiration of the permit. Such discharges shall be controlled, limited, and monitored by the permittee as specified below:
OUTFALL NUMBER AND EFFLUENT
PARAMETER(S) FINAL EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
MEASUREMENT
FREQUENCY

UNITS

DAILY
MAXIMUM

WEEKLY AVERAGE

MONTHLY AVERAGE

SAMPLE
TYPE

Outfall #001

Flovj-m3/Day

MGD

*

*

each occurrence

estimate of total
grab

Settleable Solids

ml/l/hr

1.0

once/each occurrence
30

Non-Filterable Resii ue mg/1 Total Suspended So ids)
pH - Units SU

45

once/each occurrence once/each occurrence

grab

**

**

grab

* Monitoring requi ement onl

F

** pH is measured \i pH units and is not to be avera< ed. of 6.0-9.0.

The pH is limited to the range

quarterly ; THE FIRST REPCIRT is nuF MONITORING REPORTS SHALL SE SUBMITrpn OTHER THAN TRA CE AMOUNTS. THERE SHALL BE NO DISCHARGE OF FLOA TING SOLIDS OR VISIBLE FOAM IN
B. STANDARD CONDITIONS

1. Within one year of the issuance date of this permit, the permittee shall submit a. completed CMC 105 Form C. All required analytical results shall be submitted.
2. This permit may be modified, or alternatively, revoked and reissued, to comply with any applicable effluent standard or limitation issued or approved under Sections 301(b)(2) (C), and (D), 304(b)(2) and 307(a)(2) of the Clean Water Act, if the effluent standard or limitation so issued or approved:

(a) (b)

Contains different conditions or is otherwise more stringent than any effluent limitation in the permit; or Controls any pollutant not limited in the permit.

The permit as modified or reissued under this paragraph shall also contain any other requirements of the Act then applicable.

3. Permittee shall insure that leachate and storm water runoff from the adjacent Laidlaw, Inc. Landfill shall not be discharged through Outfall #001.

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EXHIBITS 19-A THROUGH 19-WWW MINUTES OF CORPORATE DIRECTORS' MEETINGS

Produced simultaneous with, and attached separately to, the 104(e) Response of West Lake Quarry and Material Company are copies of minutes of corporate directors' meetings. Respondent hereby asserts a confidentiality claim with respect to these minutes, pursuant to §§104(e)(7)(E) and (F) of CERCLA, 42 U.S.C. §§9604(e)(7)(E) and (F), Section 3007(b) of RCRA, 42 U.S.C. §6927(b), and 40 C.F.R. 2.203(b). Following is a listing of all the minutes, together with the dates covered by each, respectively. 18-A:
19-B:

Minutes of Special Meeting of Directors of West Lake Quarry and Material Company, August 1, 1966
Minutes of Special Joint Meeting of The Board of Directors and Shareholders of West Lake Quarry and Material Company, June 30, 1971

19-C:
19-D:

Minutes of Special Meeting of Board of Directors of West Lake Quarry and Material Company, Inc., July 1, 1972
Minutes of Special Meeting of Board of Directors of West Lake Quarry and Material Company, Inc., December 28, 1972

19-E: 19-F: 19-G: 19-H: 19-1:

Minutes of Special Meeting of Board of Directors of West Lake Quarry and Material Company, Inc., May 1, 1974 Minutes of Special Meeting of Board of Directors of West Lake Quarry and Material Company, Inc., March 18, 1975 Minutes of Special Meeting of Board of Directors of West Lake Quarry and Material Company, Inc., March 16, 1976 Minutes of Special Meeting of Board of Directors of West Lake Quarry and Material Company, Inc., March 15, 1977 Minutes of Special Meeting of Board of Directors of West Lake Quarry and Material Company, Inc., September 14, 1977

19-J: 19-K:
19-L:

Minutes, Monthly Meeting of The Board of Directors of Westlake Quarry and Material Company, January 28, 1986 Minutes, Monthly Meeting of the Board of Directors of Westlake Quarry and Material Company, March 25, 1986
Minutes, Monthly Meeting of the Board of Directors of Westlake Quarry and Material Company, April 29, 1986

19-M:

Minutes, Monthly Meeting of the Board of Directors of Westlake Quarry and Material Company, June 24, 1986

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19-N: 19-O: 19-P: 19-Q: 19-R: 19-S: 19-T: 19-U: 19-V: 19-W:

Minutes, Monthly Meeting of the Board of Directors of Westlake Quarry and Material Company, July 29, 1986 Minutes, Monthly Meeting of the Board of Directors of Westlake Quarry and Material Company, August 26, 1986 Minutes, Monthly Meeting of the Board of Directors of Westlake Quarry and Material Company, September 23, 1986 Minutes, Monthly Meeting of the Board of Directors of Westlake Quarry and Material Company, October 28, 1986 Minutes, Monthly Meeting of the Board of Directors of Westlake Quarry and Material Company, November 25, 1986 Minutes, Monthly Meeting of the Board of Directors of Westlake Quarry and Material Company, January 27, 1987 Minutes, Monthly Meeting of the Board of Directors of Westlake Quarry and Material Company, February 24, 1987 Minutes, Monthly Meeting of the Board of Directors of Westlake Quarry and Material Company, March 26, 1987 Minutes, Monthly Meeting of the Board of Directors of Westlake Quarry and Material Company, April 30, 1987 Minutes, Monthly Meeting of the Board of Directors of Westlake Quarry and Material Company, June 2, 1987

19-X:
19-Y: 19-Z: 19-AA:

Minutes, Monthly Meeting of the Board of Directors of Westlake Quarry and Material Company, June 30, 1987
Minutes, Monthly Meeting of the Board of Directors of Westlake Quarry and Material Company, August 5, 1987 Minutes, Monthly Meeting of the Board of Directors of Westlake Quarry and Material Company, September 4, 1987 Minutes, Monthly Meeting of the Board of Directors of Westlake Quarry and Material Company, October 2, 1987

19-BB: 19-CC:
19-DD:

Minutes, Monthly Meeting of the Board of Directors of Westlake Quarry and Material Company, October 2, 1987 Minutes, Monthly Meeting of the Board of Directors of Westlake Quarry and Material Company, November 24, 1987
Minutes, Monthly Meeting of the Board of Directors of Westlake Quarry and Material Company, December 30, 1987

19-EE:

Minutes, Monthly Meeting of the Board of Directors of West Lake Quarry and Material Company, January 28, 1988

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19-FF:

Minutes, Monthly Meeting of the Board of Directors of West Lake Quarry and Material Company, March 4, 1988

19-GG:

Unanimous Consent of Directors of West Lake Quarry and Material Company in Lieu of Annual Meeting of Board of Directors, March 16, 1988
Minutes, Monthly Meeting of the Board of Directors of

19-HH: 19-11:

West Lake Companies, April 8, 1988
Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, April 28, 1988

19-JJ:
19-KK:

Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, June 2, 1988
Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, July 8, 1988

19-LL:
19-MM:

Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, August 19, 1988
Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, September 29, 1988

19-NN: 19-OO: 19-PP: 19-QQ: 19-RR:

Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, November 4, 1988 Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, November 17, 1988 Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, December 21, 1988 Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, February 6, 1989 Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, February 22, 1989

19-SS:
19-TT: 19-UU:

Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, March 22, 1989
Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, April 26, 1989 Statement of Unanimous Written Consent of Directors of West Lake Quarry and Material Company in Lieu of Meeting of Board of Directors, May 25, 1989

19-W:

Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, May 30, 1989

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19-WW:
19-XX: 19-YY: 19-ZZ: 19-AAA:

Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, June 23, 1989
Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, July 26, 1989 Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, September 8, 1989 Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, September 22, 1989 Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, October 25, 1989

19-BBB: 19-CCC:
19-DDD:

Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, December 8, 1989 Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, January 2, 1990
Minutes, Monthly Meeting of the Board of Directors of The

West Lake Companies, January 25, 1990
19-EEE: 19-FFF: 19-GGG: 19-HHH: 19-111: 19-JJJ: Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, February 28, 1990 Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, March 28, 1990 Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, April 20, 1990 Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, May 29, 1990 Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, June 29, 1990 Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, August 14, 1990

19-KKK: 19-LLL:
19-MMM:

Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, September 24, 1990 Minutes, Special Meeting of the Board of Directors of The West Lake Companies, October 19, 1990
Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, October 31, 1990

19-NNN:

Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, November 28, 1990

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19-OOO:

Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, December 20, 1990

19-PPP:

Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, January 31, 1991

19-QQQ:
19-RRR:

Certified Copy of Corporate Resolution of West Lake Quarry and Material Company, February 28, 1991
Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, March 6, 1991 Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, March 27, 1991

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19-SSS:

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19-TTT: 19-UUU:

Minutes, Special Meeting of the Board of Directors of The West Lake Companies, April 22, 1991 Minutes, Special Meeting of the Board of Directors of The West Lake Companies, April 23, 1991

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19-VW:
19-WWW:

Certified Copy of Corporate Resolution of West Lake Quarry and Material Company, April 30, 1991
Minutes, Monthly Meeting of the Board of Directors of The West Lake Companies, June 5, 1991

In April, 1990, Ford Financial Services Group, U.S. Real Estate authorized Dames & Moore to proceed with a Phase n Site Investigation to further document pre-transaction conditions at property adjacent to a proposed National Priorities List (NPL) site. This report presents a summary of the field techniques employed during this investigation and conclusions based upon analytical results from collected samples.
1.1 Executive Summary

The Phase n Site Investigation involved a more in-depth investigation of organic, inorganic, and radiological contamination of the Ford Property that is believed to be related to the adjacent West Lake Landfill. Upon review and evaluation of all information obtained from this investigation, several concluding remarks can be made which best summarize this effort.

First, the gamma radiation survey conducted on surface soils in areas north and west of the West Lake Landfill (i.e., areas which receive a large amount of surface runoff from the landfill) indicated that there is no significant surface radiological contamination present. Radiological contamination present within the landfill, therefore, does not appear to have contributed any significant contamination due to surface runoff to the 23 acres surveyed. Second, in addition to the surface soil survey just described which required the use of a direct-reading meter, surface soil samples where also collected from 0-12 inches in depth from property locations adjacent to the landfill and submitted for more in depth chemical and radiological analysis. Soil samples were collected in locations where contamination was suspected from the Phase I effort and in locations where contamination might reasonably be expected. Although very low levels (parts per billion) of organic contamination were provided in the analytical report for the two soil sample composites, these values were actually below the analytical limit of detection and are, consequently, not significant. Of all the soil samples collected (a total of 20), only the samples collected from the two (2) locations where radiological contamination had been indicated from the Phase I investigation had radiological contamination (i.e., the biased samples). No further surface radiological contamination beyond these biased locations is evident based upon this information and the gamma radiation survey. Third, sediment/soil samples were collected and analyzed from four (4) locations where chemical or radiological contamination might reasonably be expected to have migrated from the landfill via surface water. As with the soil samples, only low level organic chemical contamination was indicated which is likewise believed to be attributed to the sampling technique and not to actual soil contamination. Radiological contamination is also not evident in these samples.

D&M Job No. 19943-002-045 June 26, 1990

Fourth, subsurface soil conditions were also surveyed radiologically down to groundwater in several locations to the north and west of the landfill. Gamma radiation and volatile organics were measured in soil borings down to groundwater using a GM-type survey meter and a photoionization detector, respectively. Neither radiological contamination nor chemical contamination of any type was evident.

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Fifth, groundwater was sampled and analyzed chemically and radiologically by installing monitoring wells in the same soil borings that were mentioned previously. Low level (part per billion) concentrations of some organic chemicals were detected in several of the groundwater samples. Several of these, however, are believed to be attributable to background contamination from the laboratory, and as such, do not represent a significant environmental concern. Two semi-volatile BNAs (chrysene and Bis (2-ethylhexyl)phthalate) were, however, also detected in very low levels (1-27 ppb) in four (4) of the well samples. Other chemical contaminants tested for in the groundwater (i.e., metals, cyanide) were not present in sufficient concentration to represent a significant environmental concern. Although radiologically speaking there were conflicting results from the two laboratories used, there does not in any case appear to be significant groundwater contamination. The one parameter that was tested and found to be somewhat elevated in some of the water samples (gross alpha) is of secondary importance since the sum of the individual components that typically comprise this parameter failed to confirm the gross alpha totals.
With the exception of two (2) biased locations adjacent to the West Lake Landfill where radiological contamination is evident (Bl and B2), it is unlikely that the results provided from this investigation can be interpreted as evidence that the radioactive material resident in the West Lake Landfill has migrated to Earth City property.
1.2 Project History Summary

In December, 1989, Ford retained Dames & Moore to prepare an assessment of the radiologic conditions at their properties in Earth City, Missouri, as part of a pre-divestirure due diligence effort. The scope of the Phase I effort was primarily to respond to concerns raised by the proximity of the West Lake Landfill, located immediately to the east of the property under review (Figure 1). On October 23, 1989, the landfill was proposed for addition to the National Priorities List under CERCLA, due to improper acceptance during the early 1970's of radiologic materials primarily from the Department of Energy's Latty Avenue operations.

Upon completion of a review of available information, and a limited sampling effort, Dames & Moore concluded that the data suggests that significant off-site migration of radioactive contaminants from the landfill via groundwater has not occurred. However, it was recommended that surface contamination attributable to landfill runoff be further characterized.

D&M Job No. 19943-002-045 June 26, 1990

This Phase n Investigation has been developed to document more extensively field conditions by means of additional soil and water sampling for an expanded set of parameters, believed to be more representative of potential landfill contents.
1.3 flcnpe of Work Summary

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The services performed during this Phase II investigation included the following five elements:

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Overland Gamma Survey - Gamma radiation levels were measured at one centimeter and one (1) meter above the ground surface to ascertain whether additional areas of surface radioactive contamination exist;
Surface Soil Sampling - Discrete and composite soil samples were collected in the two known "hot spots", in random areas, and in one background location;

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Sediment Sampling - Discrete sediment samples were collected from drainage areas likely to be influenced by runoff from the landfill; Soil Borings/Downhole Gamma Logging - Seven soil borings were advanced to 15-25 feet depths. Cuttings were screened for organic vapors and for radiation levels. Gamma radiation levels were also measured and recorded inside the borehole, advancing in six-inch increments to the water table; and Ground water Sampling - Monitoring wells were installed at each of the borings. Samples were collected for laboratory analysis for organic, inorganic, and radiologic parameters.
2.0 OVERLAND GAMMA SURVEY

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Between April 9 and 13,1990, Dames & Moore personnel conducted an overland gamma radiation survey of 23 acres adjacent to the landfill which had not previously been surveyed. These measurements would indicate areas, if any, where radiation levels were elevated above ambient background.

D&M Job No. 19943-002-045 June 14, 1990

2.1

fjeld Investigation

The overland gamma survey covered the areas shown on Figure 2. The area to the north of the landfill, and to a lesser extent, along Old St. Charles Rock Road were surveyed to assess potential migration of radiologic materials via surface routes. Areas adjacent to the recently excavated drainage ditch/lake were surveyed to assess the levels of radiation in the material dredged from the ditch, which may have intercepted potentially contaminated groundwater.
The gamma radiation survey was set up using a 10 x 10 meter survey grid to maintain reproducibility and accuracy. Each section was first marked with stakes, using the S66 48'41" £ line, road coordinates, and chain-link fence which delineates the landfill, as the three primary reference lines. Section grid lines were established 90 degrees from the reference lines at 10 meter intervals. Three grids were established - the largest encompassed the area north of the landfill and covered approximately eight (8) acres. The second was established to the west of Old St. Charles Rock Road in an area of disturbed soils recently excavated from a nearby drainage ditch/lake. The third was also established west of Old St. Charles Rock Road and paralleled nearly the entire Ford/West Lake common boundary over an area of soils excavated from the nearby drainage ditch/lake.

Two calibrated Bicron microrem radiation survey meters were used for radiation level measurements at each intersection of the grid at one centimeter and one meter above the ground surface. These instruments use a tissue-equivalent plastic scintillator as the detection medium to provide accurate dose rate information relative to biologic tissue. An instrument operability check, which included a battery, background and source check was performed daily prior to use and several times during use, to assure property instrument operation while performing the survey. Both survey instruments were calibrated by the manufacturer and certificates of calibration are attached as Appendix A.

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2.2

Investigation Results

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Gamma radiation levels measured during the survey of the property are tabulated in Table 1. A map of the grid points is attached as Figure 3. Background radiation measurements were recorded from several areas off-site and in ambient areas located on-site. The average background dose rate for the two instruments in these areas ranged from three (3) to six (6) microrem per hour which corresponds with levels identified by ORNL in a study titled "State Background Radiation Levels 1975-1979" (report dTM-7343) which gives levels for the East St. Louis area of between four (4) and eight(8) microrem per hour. All measurements made on the property represented actual instrument readings without background data subtraction. Raw data tabulated in Table 1, represent readings obtained at each survey point one meter and one centimeter above ground surface. The primary reference point for each grid is indicated on Table 1 and the site map (Figure 3) as point 0,0. All tables give the survey point locations D&M Job No. 19943-002-045 June 14, 1990

i3f£ ur-ct-on their position relative to the reference point within the data matrix.
The U.S.Environmental Protection Agency guidelines for site cleanup and management of residual uranium and thorium (40 CFR 192, Subparts B & E) require that the exposure rate measured at a distance of one meter above the ground surface be less than 20 microrems per hour above background. In the case of the present survey, results did not exceed twice the measured background rate in any of the areas surveyed.

Contaminants located within the West Lake Landfill did not appear to influence the surface gamma radiation readings over the 23 acres surveyed. Although some fluctuations were present in the data, elevated gamma radiation readings within three times the average background measurement are not considered to be of consequence unless a systematic increase is noted. Site-wide trends were not readily apparent from the collected data.
3.0 SOIL SAMPLING

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Surface soil samples were collected at several locations to characterize existing soil conditions in areas of the site adjacent to the landfill where contamination is suspected, and where contamination might reasonably be expected.
3.1 Field Investigation

Two composite soil samples (COMP-1 and COMP-2) were collected from the areas indicated on Figure 4 (shown as Cl and C2). It is believed that the soils dredged from the ditch along Old St. Charles Rock Road has been spread over these areas. These soils were therefore sampled to indicate whether any contaminants may have settled out from surface waters carried in the ditch. Each samples was collected from six points in the area shown, and submitted for analysis for total petroleum hydrocarbons (TPH), semi-volatiles, pesticides, PCBs, herbicides, metals, and cyanide, as well as radiological parameters. Six unbiased soil samples (UB1-UB6) were collected at the locations shown on Figure 4. These areas were distributed along the general perimeter of the landfill to provide information regarding existing soil conditions. Each sample was collected at 0-6 inch depths and submitted for radiological analysis.

Biased soil samples were collected at two locations (Bl and B2) as shown on figure 4, which were identified during Phase I as having elevated gamma radiation levels. Samples Bl A, BIB, B2A, and B2B were collected at 0-6 inch depths. Samples B1C and B2C were collected at 6-12 inch depths. All six samples were analyzed for several radiological parameters.
D&M Job No. 19943-002-045 June 14, 1990

Samples were collected manually using either a stainless steel trowel or a stainless steel hand auger. Sampling equipment was decontaminated with Alconox detergent wash and a distilled water rinse between each sample. Samples requiring radiological analysis were placed in plastic bags provided by the laboratory. Organic and inorganic samples were placed in jars provided by the laboratory (Table 2) Organic and inorganic samples were placed in an iced cooler. All samples were shipped to the respective laboratories via overnight delivery accompanied by Dames & Moore chain-ofcustody records (Appendix B).
3.2 Investigation Results

A summary of organic and inorganic data is presented in Table 3. For nearly all parameters, there are no indications that samples COMP1 and COMP2 vary significantly from the background sample BKG. Exceptions of note are the results of analyses for semi-volatile compounds. No semivolatiles are indicated in the background sample, however, two compounds were detected in COMF1 and six compounds were detected in COMP 2. The semi-volatile compounds detected in the composite samples have been attributed to the sampling technique, which involved mixing the composite inside a plastic zip-lock bag. The background sample was collected directly into sample jars without contact with a bag. A summary of the radiological data for soil samples is presented in Tables 4A, 4B, 4C, and 4D. All values are reported in units of picocuries per gram of sample plus or minus the error associated with the analysis at a 95 percent confidence level (+ 2 sigma). All soil samples were analyzed for gross alpha and gross beta content and the specific nuclides uranium-234, 235/236, 238; thorium-230,232; potassium-40; cesium-137 and radium-226, 228. Values reported as less than (<) a specific value, are considered below the analytical instrument's lower limit of detection. Table 4A shows that the analytical results reported for unbiased samples UBl through UB6 are indistinguishable from the background sample collected at the same depth as well as background samples analyzed for the Phase I investigation. Biased samples collected in the two areas identified as above background in the Phase I investigation, show, as expected, elevated gross alpha and gross beta. For area 1 (Table 4B) gross alpha and gross beta for biased samples are elevated by factors of 55 and 10.6 respectively, while for Area 2 (Table 4C) levels are elevated by factors of 200 and 31, respectively. Similarly, elevated levels of uranium-234 and 238 are reported at 6.5 and 6 times background (Table 4B) and factors of 13.3 and 8.1, respectively (Table 4C). Thorium-230 values in sample B1A and BIB average over 400 times background, while B2A and B2B average over 900 times background. Thorium-232 however averaged only 3 times and D&M Job No. 19943-002-045 June 14, 1990

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6 times background for areas 1 and 2, respectively. Ra-226 concentrations in the biased soil samples analyzed from areas 1 and 2 averaged 31 and 34 times background respectively. The above results refer only to the data reported for the 0-6" sample depth. The reported concentrations for the above mentioned nuclides in the 6-12" depth are equally elevated for the area 1 sample but are somewhat lower for the area 2 sample. Composite soil sample results reported in Table 4D are indistinguishable from background.
4.0 SEDIMENT SAMPLING

Sediment samples were collected at four locations at the site to characterize existing conditions in areas where contamination might reasonably be expected to have migrated via surface water.
4.1 Field Investigation

Four sediment samples (S1-S4) were collected at the locations shown on Figure 5. Samples SI and S2 were collected from the bottom of the drainage ditch which runs along Old St. Charles Rock Road. These samples were analyzed for several radiological parameters.
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Sample S3 was collected from the bottom of a ponded area near St. Charles Rock Road. Sample S4 was collected from beneath the outlet of a surface water drain which originates at the base of the landfill berm, and emerges from the embankment of Old St. Charles Rock Road. Both samples were analyzed for organic and inorganic as well as radiological parameters.

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Samples were collected using either a stainless steel trowel or a stainless steel hand auger. Sampling equipment was decontaminated with Alconox detergent wash and a distilled water rinse between each sample.
Radiological samples were placed in plastic bags provided by the laboratory. Organic and inorganic samples were placed in jars provided by the laboratory (Table 2). Organic and inorganic samples were placed in an iced cooler. All samples were shipped to the respective laboratories via overnight delivery accompanied by Dames & Moore chain-of-custody records (Appendix B).

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D&M Job No. 19943-002-045 June 14, 1990

4.2

Investigation Results

A summary of organic and inorganic data is presented in Table 5, as a comparison with background soil sample BKG. For nearly all parameters, there are no indications that samples S3 and S4 vary significantly from the background sample. Mercury was detected only in sample S4, at 0.18 ppm only slightly above the reported detection limits.
Semi-volatile analytical results are similar to the soil samples, where several compounds were detected. Again, this is attributed to the sampling technique which involved mixing of the composite sample inside of a plastic zip-lock bag. The background sample was collected directly into sample jars without contact with a bag.
A summary of the radiological data is presented in Table 6. Review of this table shows that, for the radiological parameters specified, all data is indistinguishable from background except for the gross alpha value of sample S4 which is reported as 6.6 times background. Upon reanalysis of this sample by ITC, however, a much lower gross alpha value was obtained. For reasons explained in Section 7.1.3 of this report, the second analysis, which indicated a gross alpha level of 19.3 +. 8.6, is considered to be more valid.
5.0 SOIL BORINGS/DOWNHOLE GAMMA LOGGING

Soil borings were advanced at seven (7) locations at the site to observe and assess subsurface soil conditions to the depth of the groundwater table. Additionally, gamma radiation was measured inside each borehole to provide vertical profiles of radiation levels.

5.1

Field Investigation

Soil borings were advanced to the groundwater table at seven locations shown on Figure 6, using an ATV-mounted hollow-stem auger drill rig. Samples were retrieved using a 3-inch diameter continuous sampler. Downhole drilling equipment was decontaminated between borings by pressure washing with water. Geological observations made of the retrieved soils were maintained on Soil Boring Logs presented in Appendix D. Retrieved soils were field screened for VOCs with a photo-ionization detector, and for radiation levels with a G-M type survey meter.
Gamma radiation levels were measured inside the auger stem using an Eberline ESP-2 ratemeter and shielded SPA-3 scintillation detector. The detector was advanced in six-inch increments to depths approaching groundwater. Gamma logging measurements are shown in Tables 7-101 through 7-107, with graphical presentations in Figures 7-101 through 7-107. D&M Job No. 19943-002-045 June 14, 1990

5.2

Investigation Results

Borings depths ranged from 15 to 25 feet depending on the depth to groundwater. Soil types varied from silty to sandy silt, typically becoming coarser with depth. Some stiff silt or clay was noted. No volatile compounds were detected at any depth in any boring. Radiation levels were consistent with background levels. All gamma logging data was consistent with background levels.
6.0 GROUNDWATER MONITORING

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Groundwater monitoring wells were installed in each of the seven (7) soil borings at the locations shown on Figure 6. Well construction details are described in Section 6.1 and diagramed in Appendix E. Ten samples were collected for laboratory analysis according to the techniques discussed in Section 6.2. Analytical results are discussed in Section 6.3. 6.1 Monitoring Well Installation

As described in Section 5.0, soil borings were advanced by hollow stem auger. Upon completion of each boring, a 10-foot length of 2-inch diameter 0.010 slotted PVC well screen was placed to the bottom of the boring. PVC riser pipe was extended above the ground surface. A sand Miter-pack was placed about the well screen as the auger flights were gradually removed from the borehole, typically to 2-feet above the top of the screened interval. A 1.5 - 2 feet thick bentonite pellet seal was placed above the sand pack. In wells MW101 and MW102, a cement slurry with a bentonite additive was placed from the top of the seal to a few feet below ground surface. At all wells, a cement-aggregate mixture was placed to the ground surface to secure the steel well protector, and to form a small concrete pad to deflect surface water away from the well. The PVC riser was fitted with a PVC screw cap and a padlock was placed on the steel protector. Well construction diagrams are shown in Appendix E.
Efforts by drilling contractor Brotcke to develop MW104 on April 12 using a tank of compressed nitrogen to drive an air-lift system were not successful. On Friday, April 13, 1990, personnel returned to develop the wells using an air compressor to drive water from the well. Purging efforts were continued for 30 minutes at each of the four wells (MW101, MW102, MW103, and MW104). The three remaining wells were not accessible due to wet ground conditions, and were developed by bailing.

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D&M Job No. 19943-002-045 June 14, 1990

6.2

Sample Collection

Groundwater sampling was conducted by Dames & Moore personnel on April 17 and 18, 1990. The following procedure was used at each well.

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The depth to water from the top of the PVC casing was recorded to the nearest 1/16" using a chalked steel-tape. Standing water was purged from the well using a disposable polyethylene bailer (Voss Technologies). After removing one well volume, field measurements of temperature, pH and specific conductivity were made using a calibrated Hydac meter (Cambridge Scientific Industries) outfitted with an Orion pH probe. Field measurements were taken following each subsequent well-volume purged until three successive sets of measurements fell within the following ranges:
Temperature: pH: Conductivity: +/- 0.5° C +/-0.1pHunit +/- micromhos

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Typically, four (4) or five (5) well volumes were sufficient to accomplish stabilization. Field measurements are summarized in Appendix F. Based on contaminant levels during soil boring activities, purged water was discharged to the ground surface.

Upon stabilization, water samples were collected for laboratory analysis. Table 8 shows the volumes collected and preservations used to constitute one sample. Samples were shipped via Federal Express to the appropriate laboratories for analysis (MW109 was hand delivered to Envirodyne), under Dames & Moore chain-of-custody procedures (Appendix 8). Organic and inorganic samples were shipped in iced coolers. Each day, all VOA sample vials were placed in the same cooler, and were accompanied during shipment by trip blanks (TR-1 and TR-2).

6.3

Investigative Results

Data from organic and inorganic analyses are summarized in Table 9. Data packages from Southwest Laboratories and Envirodyne Engineers are provided in Appendix C. Data from the radiological analyses are summarized in Table 10. Data packages from ITC and CEP are provided in Appendix B. A review of the organic and inorganic data indicated that pesticides, PCBs, herbicides, and cyanide were not detected. Several VOCs were identified near or below detection levels. Methylene chloride was detected at low levels (1-26 ppb) in all samples analyzed by Southwest. Similarly, acetone was detected (3-17 ppb) in most samples. Both compounds were detected in D&M Job No. 19943-002-045 June 14, 1990
10

the Southwest QA/QC method blank, and are frequent laboratory contaminants. The absence of these compounds in the Envirodyne analysis of MW109 (duplicate of both MW102 and MW108), reinforces the interpretation that the methylene chloride and acetone results are not accurate. Low levels of 1-1 dichloroethane are indicated in well MW102 and MW109 (3 ppb and 6 ppb, respectively). Toluene, ethyl benzene, and xylene were indicated in well MW103 in low levels also. Two BNA (binuclear aromatic) compounds, chrysene and bis (2-ethylhexyl) phthalate, were also indicated in low levels in four (4) of the monitoring wells. Bis (2-ethylhexyl) phthalate was present in MW102, MW105, MW106, and MW109D while chrysene was present only in MW102. Several metals were detected at low levels as well. Copper and zinc were consistently indicated in samples analyzed by Southwest. Antimony and nickel were also indicated in approximately half of the samples by Southwest. EEI/TCT reported the presence of arsenic, mercury, selenium, and silver in the two samples which they had analyzed (MW109 and MW109D). While there is a wide disparity in the metals results presented by the two laboratories, none of the actual reported quantities are at significant levels to be of concern.
Results of radiological analyses for groundwater samples collected during the Phase II investigation are reported in Tables 10A through 10D. Due to the propensity of groundwater samples collected from wells to contain filterable soil particulates which can skew results, all samples were analyzed as raw unflltered water and as filtered water using a 0.45 micron filter medium. All results are reported as picocuries per liter of sample plus or minus the 2 sigma associated error. Numbers reported as less than (<) the reported value are below the limit of detectability for the given nuclide and analytical method. All results reported for filtered samples are indistinguishable from background data as represented by the off-site well water results of Table 2 in the Phase I report. Further, the filtered data would easily meet all existing radiological limits established for drinking water by the EPA (40 CFR 141). Of the unflltered results four samples (MW-103U, MW-105U, MW-106U, and MW-107U) would not meet the EPA gross alpha criteria of 15 pCi/1 for drinking water, but would meet all other established limits. However, since raw unflltered groundwater would not be acceptable as drinking water, this comparison serves no purpose.
7.0 CONCLUSIONS

7.1

Radiological Investigations
7.1.1 Overland Gamma Survey

I

The results of the overland gamma survey discussed in Section 2 of this report clearly show that all areas surveyed were indistinguishable from ambient radiation levels associated with D&M Job No. 19943-002-045 June 14, 1990
11

nearby off-site locations. This conclusion is further supported by the results of the unbiased and composite soil sample analyses which were also indistinguishable from background radionuclide concentrations for the Phase H investigation area. 7.1.2 Soil As discussed above, all unbiased and composite soil samples collected randomly within the 23 acres area of investigation, were found to have radionuclide concentrations similar to those measured for samples representing ambient (background) conditions collected for the present study, and those collected as background samples for the Phase I investigation. With regard to the two biased samples (Bl and B2) where contamination is evident, refer to Section 7.1.5 for details. 7.1.3 Sediment

Comparison of sediment samples to background soil samples collected for Phase I and n shows that all sediment results reported are less than or equal to the corresponding background concentration with the exception of the gross alpha result reported for sample S4. This sample was subjected to reanalysis of only the gross alpha parameter by PTC and the result reported to Dames & Moore, shown in Table 11, was 19.3 ± 8.6. The original S4 gross alpha value was not confirmed by the reanalysis. This makes the initial analytical result a highly suspect data point, in that, several of the individual nuclides analyzed are alpha emitters, namely U-234, 235/236, 238, thorium-230 and 232 and radium-226. These nuclides are by far the most abundant alpha emitters in nature and therefore their sum should represent the majority of the gross alpha activity present. Because the sum of the individual nuclides is only 7.2 pCi/g, and the analytical techniques used to measure the individual nuclides is more precise than the gross alpha measurement, especially for a medium such as soil, the gross alpha measurement must be considered of secondary importance. Further, naturally occurring nuclides which are decay products of the marker nuclides may add to the gross alpha concentration, but are considered to be in equilibrium with their parent nuclide and therefore would not add significantly to the above calculated alpha contributions of the individual nuclides.
7.1.4 Groundwater

As discussed in Section 6.3, groundwater samples were analyzed as unfiltered and filtered to provide information on the quantity of filterable, and therefore undissolved particulates, resident in the samples. All results reported in Tables 10A through 10D for filtered samples easily meet EPA drinking water standards for gross alpha (15 pCi/1), gross beta (50 pCi/1) and radium-226 + 228 of 5 pCi/1. Further, all unfiltered samples meet these criteria except for the
D&M Job No. 19943-002-045 June 14, 1990 12

gross alpha values reported for sample MW103-U, 17.2; MW105-U, 16.9; MW106-U, 101; and MW107-U, 202 pCi/1. The gross alpha values reported for these unfUtered samples are also of secondary importance since the sum of the individual nuclide concentrations fail to confirm the gross alpha values (see Section 7.1.3). Groundwater sample MW102 was also subjected to quality assurance checks having a sample duplicate analyzed and a sample split analyzed by an independent laboratory. The results of both tests confirm the results of the original analysis as reported by IT Corporation. Most values for all tests were reported as below the limit of detection. 7.1.5 Biased Soil Samples To provide additional characterization of the two limited hot spot areas identified during the Phase I study, the survey team was directed to resurvey the original areas, reidentify the location providing the highest gamma radiation level and remove 2-6" soil samples to a total depth of 12" to provide preliminary characterization of the nuclides present. These data are reported in Tables 4B and 4C. For Area 1 (Tables 4B) the major nuclides identified as significantly above background are Th-230, Ra-226, U-234, and U-238. These results are confirmed in the sample duplicate analyzed by ITC and in the sample split analyzed by CEP except for Th-230. The discrepancy in the results is due to the differences in analytical techniques used by the two laboratories. Selected analytical results reported for original samples in Table 4B were reanalyzed with results shown in Table n. The reanalysis confirmed the original test results. For Area 2 (Table 4C), the analytical parameters and major nuclides identified as present in concentrations more than 3 times background were gross alpha, gross beta, Th-230, U-234, U-238, and Ra-226. Again for sample B2A, as for B1A, the duplicate of the original sample analyzed by ITC confirmed the initial results. The split sample with CEP again did not identify Th-230 in similar quantities, nor were gross alpha and gross beta results reported by CEP similar to the ITC data. Both laboratory technique and measurement capability differences are responsible for these discrepancies. Regardless of the CEP results, any regulatory bodies which would govern cleanup of the area would consider the highest reported results for regulatory purposes and therefore the CEP data splits would become meaningless. Further, this round of soil sampling would only serve to establish the highest potential concentration of nuclides in the area based on surface gamma radiation results. Further area characterization would be required to determine the vertical and horizontal extent of the contamination before clean-up activities could proceed. Due to the elevated levels of uranium-234 and 238 as well as radius-226 in these biased samples it is likely that this material originated from the West Lake Landfill property and found its way D&M Job No. 19943-002-045
June 14, 1990 13

to the present location via surface water erosion.

pn fel
I«.

7.2

Inorganic and Organic Chemical Investigation

During the course of the Phase n investigation of the Earth City property, several different classes of both organic and inorganic contaminants were tested for in adjacent surface soils, groundwater, and drainage ditch bottom sediment. Organic contaminants tested for included total petroleum hydrocarbons (TPH), semi-volatile organics, pesticides, PCBs, herbicides, and volatile organics (VOCs). Inorganic contaminants tested for included metals and

cyanide.
7.2.1 TPH

^•m
• Zy*

-

Surface soil composite samples (2) collected from areas adjacent to the West lake. Landfill had TPH levels below background. Sediment samples (2) collected from the bottom of a ponded area near the St. Charles Rock Road and from beneath the outlet of a landfill surface water drain, likewise had TPH levels below background. 7.2.2 Semi-volatiles Low level concentrations (10-50 ppb) of several semi-volatile organic compounds were detected in both surface composite soil samples. Their presence is attributed to the sampling technique, which involved mixing the composite inside a plastic zip-lock bag. Plastic bags of this type often contain residual low level semi-volatiles. The sediment samples likewise

contained low level semi-volatiles (10-19 ppb) which can be attributed to sampling technique.
Two semi-volatile BNAs, chrysene and bis (2-ethylhexyl)phthalate were detected in levels
near or below detection limits in one and three monitoring wells, respectively, and do not represent a significant environmental concern.. 7.2.3 Pesticides, PCBs, Herbicides, Cyanide ^v?r.

&ft

.media.

There were no detectable levels of any of these contaminants in any of the three sampling

*

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D&M Job No. 19943-002-045 June 14, 1990

14

7.2.4 VOCs

Volatile organics were tested for only in the eleven (11) groundwater samples. Two (2) VOCs, methylene chloride and acetone, were present in low concentrations in virtually all groundwater samples tested. These samples were analyzed by Southwest Laboratory and both of these VOC components, which are frequent laboratory contaminants, were detected in Southwest's QA/QC method blank. Consequently, this provides further evidence that the results for these contaminants are due to background contamination from the laboratory environment and as such, are not valid.
7.2.5 Metals

For both the soil sample composites (2) and the sediment samples (2), all metals detected do not vary significantly from background levels. Groundwater samples were analyzed by two
separate laboratories: Southwest Laboratory and EEI/TCT. Low concentrations of copper, zinc, antimony, and nickel were detected by Southwest while EEI/TCT detected very low levels of

THE Cs-137 1 Ci SOURCE USED FOR THIS CALIBRATION HAS A CERTIFICATE STATING ITS TRACEABILITY TO N.B.S. (N.I.S.T.) STANDARDS. jl* INSTRUMENT CALIBRATED WITH A CS-137 GAMMA SOURCE USING A CONVERSION -' FACTOR OF 1 urera/h

Enclosed are the analytical results for your samples received in our laboratory on April 17, 1990, for the above captioned project.

All the samples were originally extracted on April 17, 1990. The acid surrogates were outside QC limits for sample MW105, MW106 and MW107. These samples were re-extracted on April 26, 1990 and re-analyzed on May 1, 1990. The acid surrogates also did not meet the recovery criteria for sample MW105 and MW106. This indicated a matrix effect. We have reported the data from the reanalyses for these three sampls. Per your request we have preformed a matrix spike and duplicate for the following samples;

MW101 (cyanide), MW105 (metals) Additional Matrix Spike/Matrix Spike Duplicates will follow with the completion of the remaining portion of this project.
If, in your review, you should have any questions or require additional information, please call.

Enclosed are the analytical results for your samples received in our laboratory on April 18, 1990, for. the above captioned project.
Sample MW110 was originally extracted on April 19, 1990. The QC/MS analysis indicated that the surrogates did not meet the QC criteria. Hence, this sample was re-extracted on April 24, 1990, and later re-analysed. The data was reported for the reanalysed sample.

Per your request we have preformed a matrix spike and duplicate for the following samples; MW102 (semi-volatile), MW108 (Herbicides), MW110 (Pesticides), MW104 (Volatile)
If, in your review, you should have any questions or require additional information, please call.

ANALYSIS SHOWS MISCELLANEOUS PEAKS WHICH CANNOT BE IDENTIFIED AS ANY SPECIFIC PATTERN. THE RESPONSE FACTOR FOR DIESEL WAS USED. NOT DETECTED ABOVE QUANTITATION LIMIT COMPOUND FOUND IN BLANK AS WELL AS SAMPLE ESTIMATED VALUE: CONCENTRATION BELOW LIMIT OF QUANTITATION UNABLE TO OUANTITATE DUE TO MATRIX INTERFERENCE

i
QA/QC SURROGATE RECOVERY NAPHTHALENE 1 0 0 V . ANALYSIS SHOWS MISCELLANEOUS PEAKS WHICH CANNOT BE IDENTIFIED AS ANY SPECIFIC PATTERN. THE RESPONSE FACTOR FOR DIESEL WAS USED. NOT DETECTED ABOVE QUANTITATION LIMIT COMPOUND FOUND IN BLANK AS WELL AS SAMPLE ESTIMATED VALUE: CONCENTRATION BELOW LIMIT OF OUANTITATIDN UNABLE TO OUANTITATE DUE TO MATRIX INTERFERENCE

1) = ANALYSIS SHOWS MISCELLANEOUS PEAKS WHICH CANNOT BE IDENTIFIED AS ANY SPECIFIC PATTERN. THE RESPONSE FACTOR FOR DIESEL WAS USED. I--ID NOT DETECTED ABOVE OUANTITATION LIMIT COMPOUND FOUND IN BLANK AS WELL AS SAMPLE = ESTIMATED VALUE: CONCENTRATION BELOW LIMIT OF QUANTITATION = UNABLE TO QUANTITATE DUE TO MATRIX TERFERENCE

1) = ANALYSIS SHOWS MISCELLANEOUS PEAK'S WHICH CANNOT BE IDENTIFIED AS ANY SPECIFIC PATTERN. THE RESPONSE FACTOR FOR DIESEL WAS USED. = NOT DETECTED ABOVE QUANTITATION LIMIT 3 = COMPOUND FOUND IN BLANK AS WELL AS SAMPLE = ESTIMATED VALUE: CONCENTRATION BELOW LIMIT OF QUANTITATION = UNABLE TO QUANTITATE DUE TO MATRIX INTERFERENCE

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MEMORANDUM
Pote: October 2, 1980

TO:

Bob Schreiber
I

From:
Subject

Burt McCuiiough
Westlake Landfill

GCT C

13SD

SCUD'WASTE -

J5 "5

Vestlake Landfill, located in Bridgeton Missouri ( S t . Louis County) has been the subject of recent Inquiry. This landfill began operation prior to state regulation. As far as our records show this landfill first opened in the aid-1960's. Fart of the landfill lies In an old quarry and part of the landfill lies in the Missouri River floodplain, approximately 1*3 miles from the river. Witnesses to this operation, whun the area of the landfill which lies in the floodplain was in operation, not<! that the fill area was often actually beneath the level of the water table. According to file materials fron Missouri Geological Survey, it is "highi.y probable that lea chat e from the landfill is entering the waters of the Missouri River. . . " Leachate from the old quarry area of the landfill is collected and hauled to USD treatment plants. Construction of onsite treatment facilities is underway. About 48,000 gallons of leachate per day is currentl; being collected. Aside from normal landfill materials, t ere are chemical industrial wastes and radiologically contaminated materials d posited in this landfill. The chemical wastes, that we know of, include about ,000 tons of residues from the production of insecticides and herbicides. These >esticide wastes were deposited b Chevron Chemical Company. Also include in the chemical wastes are waste materials from ink manufacture and from the manufacture of glue. Among the chemical wastes that we know of in West.Lake Landfill are: waste ink pigments oily sludges esters alcohols insecticides halogenated intermediates aromatics oils wastewater sluiges heavy metals asbestos herbidices

LSJ

Besides chemical hazardous wastes, in Westlake Landfill, there are radioactive wastes. During early 1973 Cotter Corporation buried radioactive Barium Sulfate Slag material and radiologically contaminated building rubbLf. There are approximately 9,000 tons of this material which contain a b o u t . ' ! £ & $ tons of natural Uranium. In October, 1977, an aerial radiological survey was done to determine the location of the burial of this contaminated material. The report from this survey indicates that there are two burial sites. One is in the center of the old quarry area, and the other is on the edge of the floodplain area which borders adjacent farmland. The U.S Nuclear Regulatory Commission has contracted Radiation Management Corporation to do extensive on-site 'radiological surveys which include groundwater analysis, core sampling, test boring, and other tests as deemed necessary. The NRC has given DNR verbal P. Teosdole Governor Division of Environmental Suciitv : Lcfser Director Robert J. Schretosr Jr.J>.E. Director

ZO~

I I I I I I I I I I I I I I I I I I
«

I

Vestlake Landfill continued Page 2 October 2, 1980 To: Bob Schreiber

permission to utilize the monitoring wells which Radiation Management Corporation will be digging, in order that DNR may test for the presence of chemical hazardous wastes.

There is little known about what went into Westlake Landfill prior to State regulation. Analysis needs to be done to determine: 1) what wastes are deposited in Vestlake Landfill, 2) if any of these pollutants are leaving the landfill via groundvater, and 3) what threat does Vestlake Landfill pos'e to drinking water supplies.
cc: Fred Lafser
Ron Kucera Jim Long Robert Robinson Bob Miller Tom Doan

A considerable arount of nslnt sludge In 55 gallon metal dnras had been disposed of on the site. It appeared that the majority of the paint slu'Jie had been nixed with soil and had caused one area to be verv odorous and uxtreaely damp. Neither the demolition cr sanitary landfill should be accepting anv quantity of !>aint or other sludftes. It is understood that a snail amount 'nijjht set into the landfill undetected but, it was obv:.ous thnt a ?OCK! nortlnn of the slud£e coulr? and should have been •? iv.^v. *medi;»te steps oust be taken to stop all : IP. ''enosit'? of utich naterl.ils and to irrondiatelv remove s-.ich r:atcsrials vhen they some how are Jinped. (Section BO-A^OIO (2) (A) of the Missouri Solid Wast<« Rules and Regulations lists the tynes of materials to be accented at a demolition landfill. Enclosed Is one conv of the Rules and Regulations.

Acceptance of non-denotion wastes has been observed it, the past at the denolition landfill site. It ia felt that it is a combination of an inadequate si«n listing the vaster to be acc»rteJ, ilr.ar'.equsts inspection of leads coMnj? in ami a willingness to accent such non-der.olition materials 'Then they . i r ? on site. c »cticr ""-A. r»l^ (2) (C) 2 raqulr=n that ft list of vautes to be sl?n i! nr?~inentlv nt "V "itc crtr.nnctss. aeccr-te : Lo ^Vrrr-vo.: *£ either entrnnce frr tho •l9-»olltlon landfill. A sirr. lirtlr." tV** v^s** to be acca^te-1. r^u^t be erected at all entrance's to tha demolition landfill. A responsible uupervlso?should he located on site who is willing to thoroughly Inspect every load th?.t ernes in and to reject all non-denolieion materials. Anyone caught dtr".pir<? non-dersolltlon wastes should be forced to renove such wastes to a proper disposal! facilltv. The eersbination of advisln-, prospective dinners of jjhat wastes are accepted via the landfill sir;n alonj with a responsible supervisor ' . * h o is knovlei;able about: what vastes can and cannot] he accepted should result in a great reduction in non-demolition wastes being dumped at the demolition landfill. 3. It wiis observed that the denolition materials vere being dumped at the top of the vorldLn* facs of the landfill and for the most part slrrply pushed over the ed«re of the f?.co. Very little compaction was beinr acconplished. It was understood that some bulky wastes such as larf.e concrete blocks and tree trunks cannot be compacted hut, the rajority of the other demolition wastes can be spread and contacted in layers around tvo feet thick on or near a 3 to 1 slope. If possible, it is recowaended that the demolition viistes be durroed at the base of Tynrkln? face. i-Thether t*"» vasten are dunped at the top or base of the working face[ every effort :sust b>s Bade to spread and ccr.pnct the demolition wastes in'ilavcrs not to e'.cced two (2) feet as mich as practical fron ' : h e stn^nnoint of the size and shape of the nat«.rlals. If a load is observed containing large materials that could hinder the oroper corroActien of oth«r demalltion wastes, it shoul'.' he durpcd where it can be r.ore easily handled instead of with the other vastes. Section 80-4.010 ( 1 2 ) (C) 1 requires that aolid waste handling equipment shall >e capahlc of : 1. Spreading in layers from »ire it to the end coapactinf the solid wastes accepted no more than tvo feet thick, when, practical and shape of the waste material, vhila confining enallest practical area.

2. Conpact the solid waste to the smallest practical volune. 3. Place, spread and contact the cover aaterial as ouch as practical.

"landfill mainly for the collection of metallic objects. It was understood that the salvaged materials are hopefully • removed fron the site the sciie <?av thev are collected. The ' landfill rust bo coTar.ended for the extensive salvage operation but, every effort nust in nn-.!e to remove the salvaged ^ . ._. nateriai Jaily or to keep than ncntly stored on sj.te.
_ . . ' 5 . It vcs observtsJ that the req-iirs*. f reive (12) inches of weekly covar mtarial lu- been atv?1..2-I an4 ha-' been properly contacted any areas t*:.it have been uro'j'.jiit up to final sradu should coat-nin final cover consisting of at least t"o fe«t of compacted soil anv! ba properly seeded. If you have any questions concerning the above cornents and recornendations, please feel free to ^ive us a call at our St. Louis Office. Reinspections vill ba r.ide to Insure that any non-demolition materials .»re not beinq Accepted and the naterials accepted are being properly compacted,

I
• I. Special Conditions and Approved Modifications A. Are there any special conditions or approved modifications or the satisfactory compliance subsections of the rules and regulations? (e.g. impermeable barrier, limited excavation, exceptions to weekly cover requirements) ' Yes B. Is the demolition landfill operation incompliance with the special conditions or approved modifications? (If "No." describe violations under "REMARKS.")

A list of wastes to be accepted shall be displayed prominently at the site ennance.
JRlO WASTE EXCLUDED

(11XO1 (11XO2

Twelve (12) inches compacied soil com material applied at least once every seven calendar days. Final cover of at least two (2) teet cotniiacted soil applied on all completed areas. Solid waste spread in layers not to eicee 1 two (2) feet as much as
pracbcal.

t 4TE SELECTION

A responsible supervisor shall be present at the disposal area at all times when the area is open to receive waste. Eieluded wastes deposited removed to an approved disposal site.
Site accessible by all-weather roads.

Solid waste compacted to smallest practical volume. Cover material compacted as much as practical. Equipment available and operated to spnad and compact the solid waste as received or at least when the accumulated wa;te reaches
200 cubic yards.

Decomposable solid wastes deposited above predicted maiimum

r

water table.

ALfTT No open burning without written permission from the agency hav- • "1 ing jurisdiction. Decomposition gases adequately vented to prevent danger to occupants of adjacent property
(13) SAFETY

No solid waste disposed of in water when the water interfered with spreading and compacting or where the water is causing a IMSquito problem. Fire eitnguishers provided on all equipment Provisions tor eitinguisnmg fires in waite. equipment or structures.

Waste Type; Organics, inorganics, solvents, pesticides, heavy metals, acids, bases, plating waste:; and radionuclides Quantity; Unknown Site Description: The site is an active landfill on the Missouri River floodplain in St. Louis County. The site has been reduced to two areas (see attached legal description).

Present Owner; William McCullough, President, Westlake Landfill, Inc., Bridgeton, MO 63042
Environmental Problems Related to Site: The site is an active permitted landfill which in the past accepted unknown quantities of hazardous wastes, Excavation at the site in the past reached the same depth as the groundwater. Unknown quantities of

hazardous materials have been deposited n direct contact with groundwater. There is potential for contamination of groundwater and the Missouri River which is less than one mi!e away, directly west of the site.
Remedial Actions at Site:

The site was surveyed prior to expansion in order to separate the demolition fill area from the area ident: :.fied as containing hazardous materials. Area of Concern Related to Site:

The average natural ground elevation is 'i35 to 440 feet with groundwater at a shallow depth. The alluvium underlying the river is one of the most important aquifers in the state. Consequently, if contamination is occuring from the landfill, it is threatening a vital aquifer resource.
General Geologic and Hydrologic Setting: LOCATION: Longitude 90 26' 45"; latitude 38 46' 15", St. Charles Quadrangle.
The landfill has been in existance for more than twenty ye.irs. For most of that time period, landfilling has occurred on the Missouri River floodplain. Landfilling also has taken place in a limestone quarry 47

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adjoining the floodplain landfill. The quarry is in the St. Louis Limestone which is present along the eastern slopes of the Missouri River floodplain.

The early portion of the landfill operation included excavation and filling below the floodplain and into the groundwater of the Missouri River aquifer. Subsequent landfill operations generally were confined to filling above the floodplain surface and also in the adjoining limestone quarry. Except where operational procedures cause outbreaks of leachat.e to occur in the quarry or runoff water to drain into the quarry, there was no evidence of significant amounts of groundwater. from the alluvial aquifer entering the limestone. For the most parit, the recharge, quite; limited to begin with, would be ;from the bedrock adjoining the alluvium into the Missouri River aquifer rather than the aquifer recharging the surrounding bedrock. Groundwater monitoring indicates contaminant movement into the alluvial aquifer in a generally northwesterly direction. However, such monitoring to date is-inadequate to verify this indication or to adequately characterize the nature of the alluvial aquifer in the vicinity of the landfill. The Missouri River floodplain sediments consist of 15 to 20 feet of silt loam to very silty clay having moderate to high permeability. The groundwater table occurs at depths of 15 to 20 feet below floodplain level. Fluctuations of 5 to 15 feet occur during periods of high water levels when there are prolonged wet seasons that (affect the Missouri River. Local wet or dry periods cause little effect other than recharge directly through the landfill. ;This may be the most significant risk posed by the Westlake Landfill,|the poor soil covering procedures that apparently occurred during landfill operation. Beneath the silt loam, very:silty clay surface soil of the alluvium, the Missouri River alluvial sediments are characterized by a general increase in grain size associated with increasing depth. The sand increase becomes noticeable at depths of 20 to 3d feet with the percentage of gravel beginning to occur at.depths of 30 to ^0 feet. These coarse sediments, plus the large and perennial recharge of the river, cause the alluvium to be one of the major and most important aquifers in the state. Consequently, if contamination is occurring from the landfill, it is threatening a vital aquifer resource. Public DrinkinR Water Advisory:

There are no public water systems located in the immediate vicinity of Westlake Landfill. However, the site is less than one mile from the Missouri River, which is the water source for St. Louis County Water Company's North Plant. The intake for that planu is about eight miles downstream from Westlake Landfill. Should contamination from the site reach the Missouri River, the downstream public water system could be affected.
Private wells located near the landfill may also be susceptible to contamination.

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Hea1th Assessment:

The Westlake Landfill site has been found to be contaminated with 4000 I tons of chlordane, trichloroethylene and toluene, and 7000 tons of low level uranium ore wastes. Chlordane is a broad spectrum insecticide that has been observed to cause the following symptoms: blurred vision, confusion, ataxia, delirium, coughing, abdominal pain, nausea, vomiting, diarrhea, irritability, tremors, convulsions, anuria, and cancer in laboratory animal:;. It attacks the central nervous system, eyes, lungs, liver, kidneys, and skin. TCE or trichloroethylene is an animal carcinogen and i:> also capable of causing the following symptoms: irritation of the eyes, nose and throat; dermatitis; headache, dizziness, vertigo, tremors, nausea and vomiting, irregular heartbeat, sleepiness, fatigue, blurred vision, unconsciousness, and death. Damage occurs to the respiratory system, heart, liver, kidneys, and central nervous system. Toluene has been observed to cause irritation of the eyes, respiratory tract, and skin; dermatitis, headache, dizziness, fatigue, muscular weakness, drowsiness, lack of coordination, staggering gait, «;kin paresthesia, collapse and coma. : Uranium is reported to cause adverse health effects in two ways: toxic chemical,effects including damage to the kidney and liver, pneumoconiosis, pronounced changes in the blood and generalized injury; and radiation effects including lung cancer, osteosarcoma, and lymphoma.
Analysis of the rates of fetal death, low birth weight, and malformations for 1972-1982 showed no rate for the ar<>a significantly higher than the state average.

A well survey and water sampling has benn completed, and an exposure questionnaire is presently being administered to selected residents near the site. This investigation by the Missouri Department of Health has found there are only four wells still i;i use in the area that are downgradient from the site. One is usei 1 only occasionally and one is not used for potable water at all. None of the wells sampled had detectable amounts of any of the chemicals dispose-i of at the site. None of the residents questioned so far appeared to have any adverse health effects caused by materials disposed of at the site. Based on available information, a healti threat exists due to the toxic effects of chemicals and low level uranium wastes buried at the site, and the possibility that off-site migration of these materials might occur. While there is no evidence of past or present exposure, the potential for future exposure exists based on the possibility that off-site migration might occur. Sampling and corrective containment and diversion should continue at. this site until risk to the public health can more accurately be determined.

Site Description: The site is part of an active landfill on the Missouri River floodplain in St. Louis County. Present Owner: Westlake Landfill, Inc., Bridgeton, MO 63042

Environmental Problems Related to Site: The site is an active permitted landfill which in thn pnst accepted 7000 tons of low level uranium ore wastes. Excavntion at the s:ite in the past reached the same depth as the groundwator. There is potential for contamination of groundwater and the Missouri River which :.s less than one mile away, directly west of the site. Remedial Actions at Site: The site was surveyed prior to expansion in order to separate the demolition fill area f-rom the area identified as containing, hazardous materials. The Missouri Department of Natural Resources is the lead agency for this site. Area of Concern Related to Site: The average natural ground elevation is 435 to 440 foot with groundwater at a shallow depth. The alluvium und srlying thn river is one of the most important: aquifers in the state. Consequently, if contamination is occuring from the landfill, it is threatening n v i t a l aquifer resource. General Geologic and Hydrologic Settiiig: LOCATION: Longitude 90 26' 45"; lati ude 38 46' 15", St. Charles Quadrangle.

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The landfill has been in existence for more than twenty yea::s. For most of that time period, landfilling has occurred on the Missouri River floodplain. Landfilling also has taken place in a limestone quarry adjoining the floodplain landfill. Tie quarry is in the St. Louis Limestone which is present along the eastern slopes of the Missouri River floodplain. The early portion of the landfill operation included excavation and filling below the floodplain and into the gronndwater of the: Missouri River aquifer. Subsequent landfill operations generally were confined to filling above the floodplain surface and also in the adjoining limestone quarry. Except where operational procedures cause outbreaks of leachate to occur in the quarry or runoff water to drain into the quarry, there was no evidence of significant amounts of groundwater from the alluvial aquifer entering the ,limestone. For tie most part, the recharge, quite limited to begin with, would be from tie bedrock adjoining the alluvium into the Missouri River aquifer rather than the aquifer recharging the surrounding bedrock. Near the bedrock quarry pit, however, the potential exists for draining some alluvial water into this sump. Apparently, the pit is dewatered on a continuous basis with the wnter pumped to discharge in the alluvial setting. Groundwater monitoring indicates general movement of the alluvial groundwater to the west nnd north.

The Missouri River floodplain sediment! consist of 15 to 20 feet of silt loam to very silty clay having moderate to high permeability The groundwater table occurs at depths of 15 to 20 feet below floodplain level. Fluctuations of 5 to 15 feet occur during periods of high water levels when there are prolonged wet seasons that affect the Missouri River. Local wet or dry periods cause little effect other than recharge directly through the landfill. This may bo. the most significant risk posed by the Westlake Landfill, the poor soil covering procedures that apparently occurred during landfill operation.
Beneath the silt loam, very silty clay surface soil of the alluvium, the Missouri River alluvial sediments are characterized by a general increase in grain size associated with increasing depth. The sand increase becomes noticeable at depths of 20 to 30 feet wjith the percentage of gravel beginning to occur at depths of 30 to 40 fee.t. These coarse sediments, plus the large and perennial recharge o' the river, c.iusc the alluvium to be one of the major and most important iquifers in the state. Consequently, if contamination is occur-ing from the landfill, it is threatening a vital aquifer resource. Public Drinking Water Advisory:
There are no public water systems located in the immediate vicinity of Westlake Landfill. However, the site is less thnn one mile f::om the Missouri River, which is the water source for St. Louis County Water Company's North Plant. The intake for thnt plant is nbout eight miles downstream from Westlake Landfill. ShoiId contamination from the site reach the Missouri River, the downstrean puhlic water system could be affected.

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Private wells located near the l a n d f i l l mny nl.so ho susceptible to contamination.

Health Assessment:

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Uranium is reported to cause adverse health effects in two ways: toxic chemical effects including damage to the kidney and liver, pneumoconiosis, pronounced changes dn the blood and ,eneralized injury; and radiation effects including lung cancer, osteosarcoma and lymphoma. Analysis of the rates of .fetal death low birth weight, and malformations for 1972-1982 showed no rate for the area significantly higher than the state average.
An exposure assessment including a well survey, water sampling, and an administrative exposure questionnaire vns completed for thu site. This investigation by the Missouri Department of Health has found there are only four wells still in use in the nren that are downgradient from the site. One is used only occasionally and one is not used for potable water at all. None of the residents questioned appeared to have any adverse health effects caused by materials disposed of nt the site-

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Based on available information, a hefilth threat exists due to the effects of low level uranium wastes buried at the site, and the possibility that off-site migration of these material might occur. While 1:here is no evidence of past or present exposure, the potent in 1 for fut.ure exposure exists based on the possibility that off-sito migration mijjht occur. Sampling and corrective containment i nd diversion should continue at this site until risk to the public health can more accurately be determined.

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ORIGIN OF MATERIAL AND HISTORY OF LICENSE

1942-1966

BEUGIN CONGO AND DOMESTIC URANIUM ORES PROCESSED AT MALLINCKRODT, INCORPORATED, AT DESTREHAN STREET FACILITY -ON NORTH SIDE OF ST, LOUIS, AGREEMENT WITH U, S, , BELGIANS WA-'flED ORE RESIDUES (DAUGHTERS) RETURfe, MATERIAL WAS HELD BY U, S,, BUT NOT OMED BY BELGIAN CONGO,
AEC-QAK RIDGE OPERATIONS OFFICE PUT OUT BID PACKAGE TO SELL, AS LISTED IN BID PACKAGE, TOTAL ORERESIDUES OF 117,050 TONS OF RAFIf^TE OR BARIUM SULFATE CAKE CONTAINING APPROXIMATELY 191 TONS OF URANIUM, THE 3700 TONS OF R*SO/j (LEACHED) CONTAINING 7 TONS OF URANIUM WAS ITEMIZED AS PART OF THIS PACKAGE,

REGION HI INSPECTION AT HAZELWOOD, MISSOURI SITE AND CANON CITY, COLORADO OFFICE.
LICENSE SUBMITS FINAL SURVEY OF LATTY AVENUE SITE TO AEC LICENSING, FINDINGS OF APRIL, 1974 INSPECTION BY REGION III ARE SENT BY LETTER FROM AEC HEADQUARTERS TO COTTER CORPORATION ADVISING THAT DILUTION AND DISPOSAL OF ORE RESIDUES ARE NOT IN KEEPING WITH INTENT OF PART 20, NO ITEMS OF INCOMPLIANCE,

CONCLUSIONS OF JUNE 22-24, AUGUST 1L 1976 INVESTIGATION
1, THE REWINING ORE RESIDUES AT LADY AVENUE SITE WERE MIXED WITH SOIL

TRANSPORTED TO THE VEST LAKE LANDFILL AS REPORTED BY THE LICENSE DURING THE APRIL 1974 INSPECTION, HOlfcVER, THE RESIDUE-SOIL MDOURE IS BY APPROXIMATELY 3 FEET OF FILL AT WEST LA!€ LANDFILL INSTtAD OF 100 FEET AS REPORTED BY THE LICENSEE, •

2, ENVIRONENTAL SOIL SAMPLES INDICATE TIE PRESENCE OF URANIUM ORE PRXESS RESIDUES REMAINING AT THE LATTY AVENU![ SITE, BETA-GAMA SURVEYS BY RIII PERSONNEL AT THAT SITE ON AUGUST 11, 1976 INDICATE LEVELS OF RADIATION IN CERTAIN AREAS THE CRITERIA ESTABLISHED BY THE NRC FOR DECONTAMINATION OF LAND AREAS PRIOR TO RELEASE FOR UNRESTRICltD USE, 3, EASED ON RADIATION IEASUREMENTS OF THK miERIAL PRESENT AT W WEST LAKE LANDFILL AND THE LATTY AVENUE SITE NEITHER LJXATION PRESENTS Afl MEDIATE RADIOLOGICAL HEALTH HAZARD TO THE PUBlilC,

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RECCWENDATIQNS

A MORE DETAILS ENVIRONMENTAL EVALUATION OF THE LATTY AVENUE AND THE VEST LAKE LAND FILL SITES SHOULD BE PERFORMED,
OAK RIDGE NATIONAL LABORATORY TO PERFORM THIS EVALUATION, ANY RECOffENDATIONS WILL BE BASED ON THE OAK RIDGE EVALUATION,

Chronology of Radioactive Waste at West Lake Landfill

United States Government (Manhattan Project)
1942-1945

Mallinckrodt (nuclear processing plant) Destrehan Street, City of St. Louis